ML090570036
| ML090570036 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/27/2009 |
| From: | Geoffrey Miller Plant Licensing Branch 1 |
| To: | Pardee C Exelon Generation Co |
| Miller, G. Edward, 415-2481 | |
| References | |
| RIS-00-017, TAC ME0362 | |
| Download: ML090570036 (10) | |
See also: RIS 2000-17
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001
February 27, 2009
Mr. Charles G. Pardee
President and Chief Nuclear Officer
Exelon Generation Company
4300 Winfield Road
Warrenville, IL 60555
SUB..IECT OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF
EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.
ME0362)
Dear Mr. Pardee:
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 Requtation 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.
An audit of OCNGS's commitment management program was performed during January and
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
acceptable program for implementing and managing NRC commitments. Details of the audit
are set forth in the enclosed audit report.
G. dward Miller, Project Man ger
Plant Licensing Branch 1-2
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-219
Enclosure: Audit Report
cc w/encl: 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
OYSTER CREEK NUCLEAR GENERATING STATION
DOCKET NO. 50-219
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 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 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 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 Oyster Creek Nuclear Generating Station (OCNGS) commitment management
program was performed at the NRC Headquarters using documentation provided by the
licensee and at the licensee's Kennett Square office during the period of January and February
2009. The audit reviewed commitments made since the previous audit in January 2004. 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
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.). Commitments made in Licensee Event Reports or in response to Notices
of Violation may be included in the sample, but the review will be 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 for verification.
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. (Note: the internal self-assessment and subsequent transition to the
Exelon Passport program was audited as an indicator of the commitment to the
process.)
(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
Table 1 contains a list of those documents that were selected for additional review during this
audit.
The NRC staff found that the licensee's commitment tracking program had captured all the
regulatory commitments that were identified by the NRC staff before the audit. The NRC staff
also reviewed plant procedures, assessment recommendations, work orders, corrective actions,
training, qualification certifications and action requests that had been initiated or revised as a
result of commitments made by the licensee to NRC.
The program has a requirement that the licensee perform an annual review and assessment of
site and corporate commitments. The most recent OCNGS annual review was reviewed by the
- 3
NRC staff. The annual review appeared thorough, addressing over 300 items. It identified
isolated concerns with procedure annotation. Further, the NRC staff found that appropriate
corrective actions were initiated.
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 OCNGS is contained in LS-AA
110 - Revision 6, "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
Table 1 contains a list of those documents that were selected for additional review during this
audit.
The NRC staff reviewed the licensee's procedure LS-AA-11 0, Revision 6,. Section 6.1 of the
procedure lists NEI 99-04 as a reference. The NRC staff found that LS-AA-11 0 generally
follows the guidance of NEI 99-04 and provides detailed instructions for making regulatory
commitments, tracking regulatory commitments, annotating documents to provide traceability of
commitments, and for making changes to commitments. Therefore, the NRC staff concludes
that the procedure used by the licensee to manage commitments provides the necessary
attributes for an acceptable commitment management program.
The NRC Staff noted that a self-assessment had been performed since the last NRC audit and
the potential concern identified in the previous NRC audit about the use of multiple commitment
tracking systems was addressed. Three recommendations from the self-assessment were
entered into the commitment tracking program and acted upon. One of the recommendations
that OCNGS transition to the Passport tracking program (Exelon fleet-wide system) from the
use of multiple programs addressed the previous potential concern. Another recommendation
addressed verification of proper annotation after the transfer. Related procedure
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport,"
was also reviewed.
The NRC staff also reviewed documents that had been created or revised as a result of
commitments made by the licensee to the NRC. The staff noted that, except as noted below,
the revised documents have annotations referring to commitments as part of the commitment
change control process. These annotations serve to prevent the commitments from
inadvertently being deleted or altered without having gone through the commitment change
process. The NRC observed that in response to one commitment (Item 1 in Table 1)
- 4
emergency procedures were revised, an operations briefing developed and the training program
augmented. It was further observed that one of the revised procedures, 2000-GLN-3200.01
(Plant Specific Technical Guidelines for the Symptom Based Emergency Operating Procedures)
was annotated consistent with the procedural requirements. However, the "EOP Support
Procedure 7" referenced in the commitment (and referenced by 2000-GLN-3200.01) was not
annotated. As a result of discussions during this audit, an entry was made into the corrective
action program to evaluate the annotation requirements and determine if there are any
extended implications.
3.0 CONCLUSION
As discussed above, the licensee's procedure used to implement and manage commitments
provides the necessary attributes for an acceptable commitment management program.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
Richard Gropp
Calvin Taylor
John Hufnagel
Pam Cowan
Principal Contributor: D. Egan
- 5
Item Source Commitment Timeframe Comments
Source: 1/24/07 Oyster Creek [emergency operations procedure] EOP Upon Procedure
1 letter 2130-07 Support Procedure 7 will be revised to direct the implementation EMG-SP7 - not annotated
20448, Operator to inject the entire contents of the Liquid Poison of approved
Summary of tank in the event that a [loss of coolant accident] LOCA is amendment. (revised parent document
Commitments. in progress. Include these EOP changes and their basis annotated)
Second item. in Licensed Operator Training, and update the EOP
(ML07031 0101 0) User's Guide to include the use of sodium penta borate RCMT 189765-48
for pH control of the suppression pool under LOCA
conditions.
Source: 7/3/08 First item on page 9: Oyster Creek will follow the Upon The commitments associated
2 letter RA-08 guidelines in Section 11.3.6.5 of NUMARC 93-01, Rev. 3 implementation with License Amendment
060, Attachment during refueling within containment. Plant procedures of approved Request are being tracked
2. First item on will be revised, as appropriate, to implement these amendment. under Passport Action
page 9 and last guidelines. Requests 642132 and
item on page 10. 828005.
(ML0819308020) Last item on oaae 10: The following secondary Note: This
containment potential openings will remain closed during License This issue is still under review
refueling activities under administrative controls: Amendment by the NRC. The
- Ventilation ductwork below siding structure on Request has commitments associated with
west side of Reactor Building (north end of west not been this License Amendment
wall) approved. Request will be implemented
- Ventilation ductwork below siding structure on as approved by the NRC.
west side of Reactor Building (south end of west
wall)
- Trunion Room Doors to Turbine Building
- Reactor Building Commodities (flanged)
penetration on north RB wall
- MAC Facility Doors
Table 1
-6
Item Source Commitment Timeframe Comments
Source; 2/2/07 The new pressure switch performance will be monitored One year after IR 567038 - Actions initiated
3 letter 2130-07 for a year to determine if periodic replacement of the [license event by the corrective action
20450, Page 4. pressure switches is warranted. report] LER program have resulted in
Corrective submittal. identifying adverse trends on
action planned [electromagnetic relief valve]
item. EMRV instruments. Actions
(ML0703803170) initiated by the [corrective
actions] have resulted in
implementing replacement of
the pressure switches and
control relays and
establishing routine
replacement [preventative
maintenance] tasks.
Source: 3/28/05 To ensure that the Standby Liquid Control system is Within 90 days Procedures
4 letter 2130-05 initiated in the event of a [large break] LOCA, the Oyster of NRC EMG-SP7, 2000-GLN
20040, Page 1 Creek [EOPs] will be revised as required. issuance of 3200.01
of attachment. license
Item listed amendment. (refer also to Item 1)
RCMT 189765-48
Table 1
-7
Item Source Commitment Timeframe Comments
Source: 3/31/05 Revise the administrative procedure for control of EOP CAP 02004 AD-OC-103, "EOP/SAM
5 letter 2130-05 documents (CC-AA-309, Control of Design Analysis) to 1986-12 was [severe accident mitigation]
20062, include instructions to use the appropriate configuration completed on Program Control," includes
Attachment 2. control process to revise the plant specific technical 12/02/2004 annotations associated with
Second item. guidelines (PSTG) Appendix C criteria. the implementation of this
(ML0509600680) commitment.
- Section 6.5.2 - CM-2,
04-213 (Steps 4.1.3.13,
4.1.3.14).
- Section 4.1.3.13 - Any
change to a design
input, setpoint, used in
Appendix C to the
PSTGs shall be
controlled in accordance
with CC-AA-102,
"Design Input and
Configuration Change
Impact Screening. (CM
2)
- Section 4.1.3.14 - All
changes to the
calculations in Appendix
C to the PSTGs shall be
controlled in accordance
with Procedure CC-AA
309, "Control of Design
Analyses." (CM-2)
RCMT
620989-05
Table 1
-8
Item Source Commitment Timeframe Comments
Source: Page 7 Actions IR
6 Attachment 3 of Completed 487012-10
Self- * Verification of proper annotation of current (references
Assessment. commitments using PassPort after data transfer. IR 528865-48)
Page 7, second (487012-10)
and third DC IR
items and Page * Transfer of data to PassPort and train site on proper 380386 -01,02,03,04, and
10 - DC items. commitment management. (487012-10) 05
Page 10 Internal actions completed as
a result of self-assessment
- Lotus Notes Database currently not site-wide
searchable and known commitments may be missed.
(IR 380386)
Commitment * Commitment Tracking Numbers08-006, 08-004 Procedural Attachment 1 from LS-AA
7 Change R1,08-002 requirements 110
Evaluation completed
Forms. Commitment changes
requiring both the need to
inform and not inform NRC
Table 1
Mr. Charles G. Pardee
President and Chief Nuclear Officer
Exelon Generation Company
4300 Winfield Road
Warrenville, IL 60555
SUB~IECT OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF
EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.
ME0362)
Dear Mr. Pardee:
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.
An audit of OCNGS's commitment management program was performed during January and
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
acceptable program for implementing and managing NRC commitments. Details of the audit
are set forth in the enclosed audit report.
Sincerely,
G. Edward Miller, Project Manager
Plant Licensing Branch 1-2
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket No. 50-219
Enclosure: Audit Report
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