ML090400875
| ML090400875 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/25/2009 |
| From: | Siva Lingam Plant Licensing Branch II |
| To: | Nazar M Florida Power & Light Co |
| Lingam, Siva NRR/DORL 415-1564 | |
| References | |
| TAC ME0454, TAC ME0455 | |
| Download: ML090400875 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 25, 2009 Mr. Mano Nazar Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
ST. LUCIE NUCLEAR PLANT - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME0454 AND ME0455)
Dear Mr. Nazar:
Once every 3 years, the U. S. Nuclear Regulatory Commission (NRC) staff is required to audit a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction L1C-105, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-1 OS, which is publicly available electronically from the Agencywide Documents Access and Management Systems 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 to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI), NEt 99-04, "Guidance for Managing NRC Commitment Changes."
An audit of S1. Lucie's commitment management program was performed at the plant site during the period February 2 through 4, 2009. The NRC staff concludes, based on the audit, that (1) S1. Lucie had implemented NRC commitments on a timely basis, and (2) S1. Lucie had implemented a program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
~<f'~
Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389
Enclosure:
Audit Report cc w/enclosures: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS ST. LUCIE NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389
1.0 INTRODUCTION AND BACKGROUND
On May 27,2003, the U.S. Nuclear Regulatory Commission (NRC) published the Office of Nuclear Reactor Regulation (I\lRR) Office Instruction L1C-1 05, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance issued by the Nuclear Energy Institute (NEI) in NEI 99-04, "Guidance for Managing NRC Commitment Changes." The current revision to L1C-105 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 ML042320463).
According to 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.)."
The audit is to be performed every 3 years.
2.0 AUDIT PROCEDURE AND RESULTS The audit was performed at the St. Lucie site during the period February 2 through 4, 2009, covering the period from May 2005 to December 2008. In accordance with L1C-105, audits consist 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.
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 those commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
Enclosure
-2 2.1.1 Audit Scope 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.). Before the audit, the NRC staff searched ADAMS for the licensee's licensing action and licensing activity submittals dated from May 2005 to December 2008. Some of these submittals contain regulatory commitments, but the NRC staff found that commitments meeting the definition in L1C-1 05 are few in number. The scope of the audit was, therefore, increased to include a sample of licensing actions that contained "implicit" commitments, such as the need to revise procedures as part of the implementation process.
Per L1C-1 05 guidelines, the audit excluded the following types of commitments:
(1) Commitments as a result of Licensee Event Reports (LERs) - These commitments are controlled by the licensee's LER process, which is imposed by Title 10 of the Code of Federal Regulations 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/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.
(4) 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.
The following documents were reviewed for this commitment audit:
(A) Licensee's letter L-2007-007 dated February 9,2007 (Agencywide Document Access and Management System (ADAMS) Accession No. ML070440348), specifically Attachment 4 (List of Commitments) of enclosure 1 associated with mitigation strategies.
(B) GL 2004-02 associated with containment sump debris.
(C) Annual summary of commitment changes implemented without prior NRC notification.
2.1.2 Audit Results Before the audit, the NRC staff reviewed reports generated by the tracking programs for the commitments to evaluate the status of completion. During the audit, the NRC staff selected a representative sample for verification between May 2005 and December 2008. The selected documents have been listed in Section 2.1.1 as (A), (B) and (C). The licensee provided the documentation to support the NRC staff's audit in each of these documents. The licensee's documentation included summary sheets providing the status of the commitment and
-3 appropriate backup documentation, as needed (e.g., plant procedures, examination records, and/or other plant documentation). The details of the audit are noted below:
(A) Attachment 4 of enclosure 1 associated with mitigation strategies listed eight commitments. Commitment 1 pertained to the development of spent fuel pool internal makeup strategies, and development of guidance in implementing these strategies. For each commitment listed, one or more actions had been assigned. For commitment 1, action number 9 had been assigned. Per the licensee's Condition Report 2007-11175, Action No.9, the licensee had revised the Off-Normal Operating Procedures 1-0350030 and 2-0350030, "Fuel Pool Cooling system," for St. Lucie Units 1 and 2 respectively.
Similarly, the status of other actions associated with the rest of the seven commitments had been verified, and found to be closed.
(B) For GL 2004-02 associated with containment sump debris, Condition Report 2005-17132 provided the tracking of all actions and associated commitments.
(C) The licensee provided the annual summary of commitment changes implemented without prior NRC notification for calendar years 2005 on February 14, 2006 (ADAMS Accession No. ML060670266), 2006 on February 6, 2007 (ADAMS Accession No. ML070450229), 2007 on February 21,2008 (ADAMS Accession No. ML080660084), and 2008 on February 24, 2009. A cursory review of these commitments indicated that the licensee had properly documented the evaluations as required by ADM-25.05.
The NRC staff found that the licensee's commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before and during the audit. The NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit.
2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The NRC staff reviewed the licensee's procedure ADM-25.05, Revision 2, "NRC Commitment Management Program," against NEI 99-04. In particular, Section 1.0, "Purpose," specifically states that the procedure is based on NEI-99-04. In general, the NRC staff found that ADM-25.05, Revision 2, follows closely the guidance of I\IEI-99-04: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments. Attachment 1 of ADM-25.05, Revision 2, provides detailed instructions regarding making changes to a commitment. ADM-25.05, Revision 2, also contains a data sheet to document the evaluation and approval of changes.
The Licensing Manager is responsible for the commitment management program. The audit determined that the Licensing Department staff was maintaining appropriate records of commitments and commitment changes.
Procedure ADM-25.05, Revision 2, says commitments will be tracked in the Station Issue Tracking and Information System (SITRIS), which is part of the Florida Power & Light corporate corrective action process.
-4 The NRC staff reviewed examples of open-item tracking in the SITRIS. The SITRIS indicates the required action, responsible party, and indicates the status. Internal due dates are generally established in advance of the formal commitment date to ensure implementation and closure prior to the date committed to the NRC. Closure requires completed actions (e.g., completed modification or issued procedure revision).
Procedure ADM-25.05 contains detailed instructions regarding changes to commitments, including the need to inform the NRC. If the changes were evaluated as needing prior NRC notification, they were included in an annual summary report. The NRC staff reviewed a sample of these change evaluations and found that they had been properly documented as required by ADM-25.05. As a result of review of the licensee's information, the !'JRC staff found no reason to differ from the licensee's reported status of the audited commitments. Thus, 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 that, based on the above audit, (1) the licensee had implemented or is tracking for future implementation regulatory commitments; and (2) the licensee had implemented a program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Don Cecchett, Kenneth Frehafer and Eric Katzman Principal Contributors: Siva P. Lingam and Jason Paige
February 25, 2009 Mr. Mano Nazar Senior Vice President, l\Juclear and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420
SUBJECT:
ST. LUCIE NUCLEAR PLANT - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME0454 AND ME0455)
Dear Mr. Nazar:
Once every 3 years, the U. S. Nuclear Regulatory Commission (NRC) staff is required to audit a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction L1C-105, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-105, which is publicly available electronically from the Agencywide Documents Access and Management Systems Public Electronic Reading Room on the Internet at the NRC web site (Accession l\Jumber ML022750041), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI), NEI 99-04, "Guidance for Managing NRC Commitment Changes."
An audit of S1. Lucie's commitment management program was performed at the plant site during the period February 2 through 4, 2009. The NRC staff concludes, based on the audit, that (1) S1. Lucie had implemented I\JRC commitments on a timely basis, and (2) S1. Lucie had implemented a program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, IRA!
Siva P. Lingam, Project l\IIanager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389
Enclosure:
Audit Report cc w/enclosures: Distribution via Listserv DISTRIBUTION:
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