ML083290080
| ML083290080 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/05/2008 |
| From: | Feintuch K Plant Licensing Branch II |
| To: | Jerrica Johnson Southern Nuclear Operating Co |
| Feintuch K, NRR/DORL/LPL2-1, 415-3079 | |
| References | |
| TAC MD9847, TAC MD9848 | |
| Download: ML083290080 (14) | |
Text
December 5, 2008 Mr. J. Randy Johnson Vice President - Farley Joseph M. Farley Nuclear Plant 7388 North State Highway 95 Columbia, AL 36319
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - AUDIT OF THE LICENSEE=S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS.
MD9847 AND MD9848)
Dear Mr. Johnson:
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 Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, commitment management program was performed at the plant site on October 27 and 28, 2008. The NRC staff concludes, based on the audit, that Southern Nuclear Operating Company (the licensee) has implemented NRC commitments on a timely basis, and (2) the licensee has implemented an effective program for managing NRC commitment changes at FNP, Units 1 and 2. The details of the audit including the NRC staffs observations and recommendations are set forth in the enclosed audit report.
J. 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) 415-3079.
Sincerely,
/RA/
Karl Feintuch, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
Audit Report cc w/encl: Distribution via ListServ
ML083290080 OFFICE LPL2-1/PM LPL/2-1/LA LPL2-1/BC NAME KFeintuch GLappert MWong (LOlshan for)
DATE 12/04/08 11/24/08 12/05/08
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SOUTHERN NUCLEAR OPERATING COMPANY, INC.
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364
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.). The audit is to be performed every 3 years.
2.0 AUDIT PROCEDURE AND RESULTS An audit of the Joseph M. Farley Nuclear Plant, Units 1 and 2 commitment management program was performed at the plant site on October 27 and 28, 2008. The audit reviewed commitments made since the previous audit on August 16 and 17, 2004, which was issued as an Audit Report on June 9, 2005. 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, relief requests, etc.) or licensing activities (bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation could be included in the sample, but the review is 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 since the last audit and selected a representative sample of regulatory commitments for verification. The identified list of commitments was forwarded to the licensee with a request to locate documentation for the listed regulatory commitments ahead of the NRC staffs visit.
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 (Implementation)
Southern Nuclear Operating Company (the licensee) has implemented Procedure FNP-0-SYP-21.0, ANRC Commitment Management,@ which identifies the methods and site organization tools for managing development, review, and implementation of station commitments and FNP-0-AP-1, Methods for Changing NRC Commitments which identified methods and site organization tools for changing, updating or revising NRC Commitments. A commitment tracking system (CTS) database is used in conjunction with other information sources to address and track regulatory 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., 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 NRC staffs 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.
As discussed above, the CTS and commitments material change evaluation (CMCE) provided by the licensee=s procedures STA-509 and REG-509, provide acceptable tools for the licensee to capture the NRC guidance on commitment management programs. The licensee enters the regulatory commitments made to the NRC into a database. The regulatory commitments are labeled as NRC commitments. Each commitment is numbered and described by a commitment title and brief description. Status of the commitments, implementation dates, target implementation (documents which finally capture the commitment) document information associated with each specific commitment, and comments are captured in the database.
The NRC staffs audit of the licensees commitment management program for FNP, Units 1 and 2 did not identify any regulatory commitments that were not satisfied or incorporated. The licensee has maintained the database well and all the commitments selected for this audit were easily traceable in the database. In case the commitment was already incorporated, the database provided a status of the commitment providing reference to the implementation document.
Based on the results of the on-site audit, the NRC staff concludes that 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 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 FNP, Units 1 and 2, is contained in procedures FNP-0-SYP-21.0, ANRC Commitment Management,@ and FNP-0-AP-1 Methods for Changing NRC Commitments. The primary focus of the audit was to ensure that the commitments are implemented without a change and if a change is made, it is in accordance with the approved plant procedures. The audit also verified 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 (Managing Changes)
Detailed processes are outlined by which the licensee carries out obligations under its regulatory commitments. Changes to obligatory commitments are reported to the NRC in accordance with the recommendations of LIC-105.
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 As an observation the NRC staff notes that the licensee has not conducted an internal audit of the Regulatory Commitment Management System since the last NRC Regulatory Commitment Audit. The NRC staff recommends that the licensee conduct an internal audit of the Regulatory Commitment Management System as soon as practical and establish a frequency of future audits based on the internal audit results.
4.0 CONCLUSION
Based on the results of the audit, the NRC staff concludes that the licensee has implemented the regulatory commitments management program effectively, and implemented regulatory commitment changes appropriately, in accordance with LIC-105 and consistent with NEI 99-04.
5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Aimee Gray C. Howard Mahan Walter Sims Principal Contributors: K. Feintuch G. Lappert Date: December 5, 2008
Attachment:
Regulatory Commitments and Summary of Audit Results
Joseph M. Farley Nuclear Plant, Units 1 and 2 Letter Number and Date Subject Farley Commitment No.
Description of Commitment Implementation Status Application Dated 04/27/2007, NL-07-0067 Licensing Correspondence (LC) # 14518 Updated in NL-08-0517 LC # 14744 Dated 05/12/2008 Issued in NRC letter/Amendment LC # 14842 Dated 09/29/2008 Amendment Nos. 178 and 171, which allows CTMT Personal Air Lock to be Open During Fuel Movement (In this table all references to amendment numbers are in the order of Unit 1 and Unit 2 respectively)
Commitment (CMT) No.
10905, Action Item (AI) No.
AI2008206414 Original Commitment Statement:
SNC procedures will ensure that the containment equipment hatch is installed and containment personnel air locks have at least one door closed promptly following a fuel handling accident inside containment.
Revised by letter dated May 12, 2008:
SNC procedures will ensure that the containment equipment hatch is installed and containment personnel air locks have at least one door closed promptly following a fuel handling accident inside containment. The designated trained hatch closure crew will be augmented to include additional personnel to have one door in each personnel lock closed following evacuation of containment.
CLOSED:
Commitment statement changed with letter dated May 12, 2008.
Work order completed and implementation in FNP-0-STP-610, Version 9.
Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10804 FNP-l will perform MRP-139 mitigation and post-mitigation examination activities on the pressurizer nozzles by the end of the lR21 outage (Fall 2007).
CLOSED:
Initial letter dated January 30, 2007, superseded by Letter dated February 21, 2007, superseded by letter dated March 6, 2007.
Commitment closed with letter dated November 12, 2007 to the NRC, LC # 14673, NL-07-2116.
Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10805 FNP-2 will perform MRP-139 required examinations on four pressurizer Alloy 82/182 butt welds (identified in the table on page EI-6) during the 2Rl8 outage (Spring 2007).
CLOSED:
AI 2007200505 LC # 14604, NL-07-1317 dated 07/18/2007 Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10806 FNP-2 will perform MRP-139 mitigation and post-mitigation examination activities on the pressurizer nozzles by the end of the 2R20 outage (Spring 2010).
OPEN:
AI 2007200506 LC # 14604, NL-07-1317, 07/18/2007
Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10807 If a shut down occurs due to excessive primary system unidentified leakage, and if the leakage cannot be confirmed to originate from a source other than the pressurizer nozzles, a bare metal visual examination of Alloy 82/182 weld locations on the pressurizer will be perfumed to determine whether the leakage originated at those locations.
CLOSED:
Incorporated into Procedures FNP-1-STP-9 Updated in Ver 39 and FNP-2-STP-9 Updated in Ver 34 Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10808 Examinations of pressurizer weld overlays will be performed in accordance with MRP-139 and/or NRC approved alternatives.
CLOSED:
Incorporated into procedure NMP-ES-024-507.
Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10809 SNC will report to the NRC within 60 days of restart details of examination results of any unmitigated weld examinations and any corrective or mitigative action taken. SNC will report bare metal visual examination results to the NRC within 60 days of restart CLOSED:
Incorporated into NL Submittals Lists.
Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10810 Processes described in Enclosures 1 & 2 for monitoring primary system leakage will be used until Alloy 82/182 butt weld locations on the pressurizer have been mitigated or examined.
CLOSED:
Incorporated into procedures FNP-1-STP-9 Updated in Ver 39, FNP-2-STP-9 Updated in Ver 34 Farley letter dated 03/06/2007, NL-07-0483 LC # 14548 Examination and Mitigation of Alloy 82/182 Pressurizer Butt Welds CMT 10811 FNP-2 will perform MRP-139 reexaminations on two pressurizer Alloy 82/182 butt welds (identified in the table on page EI-6) prior to 10/2009.
CLOSED:
FNP Unit 2 - 4th 10-Year Vol 4 ISI (InSevice Inspection)
GL2004-02 Potential Impact of Debris Blockage on Emergency recirculation during Design Basis Accidents at Pressurized Water Reactors LC # 14222 -
No CMTs LC # 14306 -
CMT 10769, 10823 LC # 14642 -
No CMTs LC # 14693 -
CMT 10882 LC # 14707 -
CMT 10882 CMT 10769 - Installation of Unit 1 and Unit 2 new post LOCA containment sump recirculation screens, completion of required modifications and implementation of required procedural changes.
CMT 10823 - Procedure enhancements will be made to clearly identify labels that label and signs that have been evaluated for use in containment during the LOCA environment.
CMT 10882 - FNP will be in compliance with the regulatory requirements listed in the Applicable Regulatory Requirements section of GL 2004-02. With exception CMT 10769 - OPEN CMT 10823 - CLOSED:
incorporated into procedures:
FNP-1-STP-34 Ver 30, FNP-1-STP-34.1 Ver 30, FNP-2-STP-34 Ver 22, FNP-2-STP-34.1 Ver 22 CMT 10882 - CLOSED:
LC # 14746 Dated 04/29/2008 Regarding the SI throttle valve replacement, the outage was in progress during the time of the audit.
CMT 10899 - CLOSED:
of the previously approved extension for Unit 2 SI throttle valve replacement scheduled to be completed in the Fall 2008 refueling outage. Extension approved in NRC letter dated August 29, 2007.
CMT 10899 - SNC will update the engineering guidance procedure that is part of the design change process to include guidance for reviewing the impact of a proposed change on the documentation that forms the design basis for the response to Generic Letter 2004-02 incorporated into procedure ENG-008 Version 9.0, Section D.2.9 Submittal LC # 14073 07/28/2004 Approval LC # 14240 03/08/2005 Amendment Nos. 168 and 160 LC 14073 -
CMT 10646 LC # 14240 -
CMT 10754, 10756 Each licensee should make a regulatory commitment to provide to the NRC using an industry database the operating data (for each calendar month) that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report," by the last day of 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 Consolidated Data Entry (CDE) program, currently being developed and maintained by the Institute of Nuclear Power Operations).
CMT 10646 - CLOSED:
Closed to CMT 10756 CMT 10754 - CLOSED:
Ops issued TS Amendments 168 and 160 CMT 10756 - CLOSED:
Incorporated into procedure FNP-0-AP-54 Ver 6 NL-07-2266 dated 12/20/2007 LC # 14699 CMT 10883 -
10889 (item numbers 1-7) lists 7 commitments These will be reviewed individually. Please provide all information pertaining to each commitment.
- 1) The proposed changes to the Farley Technical Specifications will be CMT 10883 - OPEN:
10889 are all still open pending approval of the Amendment Request by the NRC.
AI 2007205798 was used to initiate
implemented within 90 days of NRC approval.
- 2) Test or maintenance activities that degrade the availability of the auxiliary feedwater system, RCS pressure relief system (pressurizer PORVs and safety valves), AMSAC, or turbine trip should not be scheduled when a logic train or RTB train is inoperable for maintenance.
- 3) One complete ECCS train that can be actuated automatically must be maintained when a logic train is inoperable for maintenance.
- 4) Test or maintenance activities that cause master relays or slave relays in the available SSPS train to be unavailable and test or maintenance activities that cause analog channels to be unavailable should not be scheduled when a SSPS logic train or RTB train is inoperable for maintenance.
- 5) Test or maintenance activities on electrical systems (e.g., AC and DC power) and cooling systems (e.g., service water and component cooling water (CCW only for an inoperable logic train>> that support the systems or functions listed in commitments 2 through 4 above should not be scheduled when a SSPS logic train or RTB train is inoperable for maintenance. That is, one complete planning for implementation.
When amendment approval is issued by the NRC AIs will be written to implement the commitments.
train of a function listed in this commitment that supports a complete train of a function noted above in commitments 2 through 4 must be available.
- 6) Implement program to monitor RTS and ESFAS protection system equipment unavailability and component failures to ensure consistency with WCAP-I0271, WCAP-14333, and WCAP-15376 modeling assumptions.
- 7) For channels with built-in bypass capability, or for inoperable channels bypassed for surveillance testing of other channels, implement administrative controls to ensure that analog channels are not routinely removed from service at-power for channel calibration, if such calibration would take more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.