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-110, 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
1
Source: 1/24/07
letter 2130-07
20448,
Summary of
Commitments.
Second item.
(ML07031 01010)
Oyster Creek [emergency operations procedure] EOP
Support Procedure 7 will be revised to direct the
Operator to inject the entire contents of the Liquid Poison
tank in the event that a [loss of coolant accident] LOCA is
in progress. Include these EOP changes and their basis
in Licensed Operator Training, and update the EOP
User's Guide to include the use of sodium pentaborate
for pH control of the suppression pool under LOCA
conditions.
Upon
implementation
of approved
amendment.
Procedure
EMG-SP7 - not annotated
(revised parent document
annotated)
RCMT 189765-48
2
Source: 7/3/08
letter RA-08
060, Attachment
2. First item on
page 9 and last
item on page 10.
First item on page 9: Oyster Creek will follow the
guidelines in Section 11.3.6.5 of NUMARC 93-01, Rev. 3
during refueling within containment. Plant procedures
will be revised, as appropriate, to implement these
guidelines.
Last item on oaae 10: The following secondary
containment potential openings will remain closed during
refueling activities under administrative controls:
Ventilation ductwork below siding structure on
west side of Reactor Building (north end of west
wall)
Ventilation ductwork below siding structure on
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
Upon
implementation
of approved
amendment.
Note: This
License
Amendment
Request has
not been
approved.
The commitments associated
with License Amendment
Request are being tracked
under Passport Action
Requests 642132 and
828005.
This issue is still under review
by the NRC. The
commitments associated with
this License Amendment
Request will be implemented
as approved by the NRC.
Table 1
- 6
Item Source
Commitment
Timeframe
Comments
3
Source; 2/2/07
letter 2130-07
20450, Page 4.
Corrective
action planned
item.
The new pressure switch performance will be monitored
for a year to determine if periodic replacement of the
pressure switches is warranted.
One year after
[license event
report] LER
submittal.
IR 567038 - Actions initiated
by the corrective action
program have resulted in
identifying adverse trends on
[electromagnetic relief valve]
EMRV instruments. Actions
initiated by the [corrective
actions] have resulted in
implementing replacement of
the pressure switches and
control relays and
establishing routine
replacement [preventative
maintenance] tasks.
4
Source: 3/28/05
letter 2130-05
20040, Page 1
of attachment.
Item listed
To ensure that the Standby Liquid Control system is
initiated in the event of a [large break] LOCA, the Oyster
Creek [EOPs] will be revised as required.
Within 90 days
of NRC
issuance of
license
amendment.
Procedures
EMG-SP7, 2000-GLN
3200.01
(refer also to Item 1)
RCMT 189765-48
Table 1
- 7
Item
Source
Commitment
Timeframe
Comments
5
Source: 3/31/05
letter 2130-05
20062,
Attachment 2.
Second item.
Revise the administrative procedure for control of EOP
documents (CC-AA-309, Control of Design Analysis) to
include instructions to use the appropriate configuration
control process to revise the plant specific technical
guidelines (PSTG) Appendix C criteria.
CAP 02004
1986-12 was
completed on
12/02/2004
AD-OC-103, "EOP/SAM
[severe accident mitigation]
Program Control," includes
annotations associated with
the implementation of this
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
6
Source:
Attachment 3 of
Self-
Assessment.
Page 7, second
and third DC
items and Page
10 - DC items.
Page 7
- Verification of proper annotation of current
commitments using PassPort after data transfer.
(487012-10)
- Transfer of data to PassPort and train site on proper
commitment management. (487012-10)
Page 10
- Lotus Notes Database currently not site-wide
searchable and known commitments may be missed.
(IR 380386)
Actions
Completed
IR
487012-10
(references
IR 528865-48)
IR
380386 -01,02,03,04, and
05
Internal actions completed as
a result of self-assessment
7
Commitment
Change
Evaluation
Forms.
- Commitment Tracking Numbers08-006, 08-004
R1,08-002
Procedural
requirements
completed
Attachment 1 from LS-AA
110
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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