ML090400172
| ML090400172 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/18/2009 |
| From: | Nadiyah Morgan Plant Licensing Branch 1 |
| To: | Sena P FirstEnergy Nuclear Operating Co |
| morgan n | |
| References | |
| TAC MD9851, TAC MD9852 | |
| Download: ML090400172 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 18, 2009 Mr. Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS.
MD9851 AND MD9852)
Dear Mr. Sena:
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC [Nuclear Regulatory Commission] Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) 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 those regulatory commitments are being effectively implemented.
An audit of Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) commitment management program was performed on site during the period October 28 - October 29, 2008.
Based on the audit, the NRC staff concludes that FirstEnergy Nuclear Operating Company: (1) has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
P.Sena
- 2 If you have questions or concerns, please contact me at (301) 415-1016.
Sincerely, Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosure:
As stated cc w/encl: Distribution via Listserv
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412
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 Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) 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 (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 those regulatory commitments are being effectively implemented.
According to NRR's Office Instruction L1C-105, which cites the definition from NEI-99-04, a "regulatory commitment" is 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. L1C-105 further directs 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, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.).
2.0 AUDIT PROCEDURE AND RESULTS An audit of the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) commitment management program was performed onsite at the FirstEnergy Nuclear Operating Company administration buildinq during the period October 28 - October 29, 2008. 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 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 Before the audit, the NRC staff searched ADAMS for a sampling of the licensee's licensing actions dated within the past 3 years. NRC staff identified documents containing regulatory commitments meeting the criteria specified by L1C-1 05. Table 1 lists the licensee's commitments which were audited.
The list of the selected regulatory commitments for BVPS-1 and 2 was provided to the site licensing group with a request to provide plant documentation used to track each individual commitment. Also, the site personnel were requested to provide status and a copy of the revised documents (plant procedures, Updated Final Safety Analysis Report (UFSAR),
Technical Specifications (TSs), etc.) for verification, if the required actions had already been completed. The regulatory commitments were reviewed against the plant documents to verify if the commitment had been implemented satisfactorily in accordance with the approved plant procedures.
L1C-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, generic letters, etc.). Accordingly, the audit excludes the following types of commitments:
(1)
Commitments as a result of Licensee Event Reports (LER)s - These commitments are controlled by the licensee's LER process, which is imposed by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.73.
(2)
Commitments made on the licensee's own initiative among internal organizational components.
(3)
Commitments that pertain to milestones of licensing actions or 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 or activity was completed.
(4)
Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, TSs, and UFSARs. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
- 3 2.1.2 Audit Results The NRC staff reviewed the commitments listed in Table 1 to ensure that the selected commitments are included in the plant database used to track the commitments and evaluate the status of completion of each commitment. The NRC staff found that the licensee's commitment tracking program had captured the regulatory commitments that were identified by the NRC staff before the audit.
The NRC staff also reviewed plant procedures and other design bases documents that had been revised as a result of commitments made by the licensee to NRC. These procedures and documents are identified in the right-hand column of Table 1. The NRC staff review indicated that:
- 1.
All the regulatory commitments selected for the audit were being tracked.
- 2.
The actual status of each regulatory commitment was properly documented.
- 3.
Review of the plant documents for the completed regulatory commitments indicated that the commitments were implemented as previously described.
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 BVPS-1 and 2 is contained in the 1/2-ADM-2204, Commitment Management. 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.
2.2.1 Audit Results The NRC staff reviewed the licensee's procedure 1/2-ADM-2204, Commitment Management, against NEI 99-04 guidelines. In particular, in regards to managing a change or deviation from a previously completed commitment, Section 1.0 specifically states that the procedure is based on and implements the recommendations of NEI 99-04. In general, 1/2-ADM-2204, Commitment Management follows closely the guidance of NEI-99-04: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments.
- 4 As set forth in Section 2.1 above, the NRC staff found that the licensee had properly addressed all the regulatory commitments selected for this audit. As a result of the review of the licensee's 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. Thus, the NRC staff judges that the procedure used by the licensee to manage commitments is appropriate and effective.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit, (1) the licensee had implemented or is tracking for future implementation its regulatory commitments; and (2) the licensee had implemented an effective program to manage changes to regulatory commitment.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Thomas Miller Principal Contributor: N. Morgan Date: February 18, 2009
TABLE 1 BEAVER VALLEY POWER STATION AUDIT OF WRITTEN LICENSEE COMMITMENTS (2005 THROUGH 2008)
Application Info lAC NO.
Commitment Licensee Implementation Status Documents Reviewed 2/11/2005 L-05-006 Attachment C ML050480440 SE issued 2/6/2006 ML060100325 MC3394 MC3395 Complete and submit a re-analysis of Large Break LOCA for BVPS-1
& 2 within one year following implementation of containment conversion.
(Feb - Oct 2006)
Completed
- Corrective Action Form
- !\\IRC approved Amd No. 272 (02/06/06)
-Paperwork from a local database 2/9/2007 L-07-017 ML070440341 MD4291 Revise BVPS-2 operating procedures to instruct the operators to secure a train of the Completed (5/9/2008)
-Commitment Tracking Orders
-EOP SE issued 3/11/2008 ML080420549 recirculation spray system if no service water is available for that train, prior to 5/2008.
10/31/2005 L-05-164 ML053110146 Perform spot Radiographic Testing examination of the Completed (4/27/2006)
-Commitment Evaluation Form
-Vendor completed full penetration steel liner plate weld during the BVPS-1 outage scheduled for February 2006.
Technical Info Review Form 12/6/2005 L-05-056 ML053480357 FENOC radiation protection personnel will be provided additional training for selection, approval, issue, equipment set-up, operation and maintenance instructions Completed 12/19/2006
-General Action Item form
- Commitment Evaluation Form
-RP Program OP for the Delta Protection Supplied-Air Containment Mururoa I
V4 MTH2 Suits.
(12/4/06) -12/28/06
- 2 Application TAC NO.
Commitment Licensee Documents Info Implementation Reviewed Status 4/7/2006*
MD1140 Eddy current Completed
-Commitment L-06-044 examination will be used Tracking order ML061020306 MD1141 to supplement
-Reactor vessel ultrasonic examination of exam summary SE issued the volume immediately Unit 1 10/23/2006 under the surface for the ML062790072 nozzle-to-safe end or safe end-to-pipe welds when sufficient surface roughness calls into question the applicability of the ultrasonic examination qualification to detect axial flaws.
3/8/2007**
MD4828 The installed weld Completed L-07-143 L-07-039 overlay will be added to (10/29/2007)
Pressurizer Weld ML070720511 the BVPS-1 lSI Plan in Overlay Exam accordance with Report SE issued Subarticle Q-4300 of 9/17/2007 Nonmandatory Appendix ML072050488 Q for at least one inservice examination.
1/11/2007
- MD4020, The staff of the BVPS-1 Completed Revised TS L-06-172
- MD4021, and 2 will establish TS (10/12/2007)
Bases pages ML070170390 Bases for LCO 3.0.8, MD4022 which will provide SE issued guidance and details on 6/14/2007 how to implement the ML071300203 new requirements of LCO 3.0.8.
12/7/2006***
- MC6285, Include in the Bases for Completed
- MC6286, ITS 3.8.4, DC Commitment ML063450214 MC6579 Sources - Operating the Tracking
- MC6612, requirement to
-Calculation SE issued MC6614 maintain at least a 5%
Addendum 2/21/2007
- MC6626, design margin for the ML070160593 MC6783 MC6792 EnerSys model 2GN-13 batteries (Unit 2 Batteries 2-3 and 2-4) and a least a 2%
design margin for the EnerSys model 2GN 21 batteries (Unit 1
- 3 Application Info TAC NO.
Commitment Licensee Implementation Status Documents Reviewed Batteries 1-1 and 1-2 and Unit 2 Batteries 2-1 and 2-2).
3/10/2006 MC4645 The Power Ascension Completed
-SAP L-06-035 Test Plan will be
-General Action ML060750572 MC4646 approved and implemented prior to power ascension for BVPS-2. The plan will Item Order SE issued include provisions for 7/19/2006 recording and analyzing ML061720376 data at each power incremental increase (as noted in Figure 2 of L 06-035) to confirm that the response is as expected and the acceptance criteria are met.
- The following commitment applies to reactor nozzle-to-safe end, nozzle-to-piping and safe end-to-piping welds examined from the inner diameter surface. Examinations conducted during the remainder of the third 10-Year Inservice Inspection Interval at BVPS-1 and second 10-year Inservice Inspection Interval at BVPS-2.
- To be completed within the next two refueling outages but no later than the end of 1R20.
Maintenance and refueling outage 1R20 is currently scheduled to end October 28, 2010.
P.Sena
- 2 If you have questions or concerns, please contact me at (301) 415-1016.
Sincerely,
/raJ Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
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