ML091540661
| ML091540661 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/15/2009 |
| From: | Peter Bamford Plant Licensing Branch 1 |
| To: | Pardee C Exelon Generation Co, Exelon Nuclear |
| Bamford, Peter J., NRR/DORL 415-2833 | |
| References | |
| RIS 2000-17, TAC ME1086, TAC ME1087 | |
| Download: ML091540661 (9) | |
See also: RIS 2000-17
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001
June 15, 2009
Mr. Charles G. Pardee
President and Chief Nuclear Officer
Exelon Nuclear
Exelon Generation Company, LLC
4300 Winfield Road
Warrenville, IL 60555
SUB~IECT: LIMERICK GENERATING STATION, UNITS 1 AND 2 - AUDIT OF EXELON
GENERATION COMPANY, LLC'S MANAGEMENT OF REGULATORY
COMMITMENTS (TAC NOS. ME1086 AND ME1087)
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 Nuclear Regulatory
J
Commission (NRC) informed licensees that the Nuclear Energy Institute (I'JEI) 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.
An audit of the commitment management program for Limerick Generating Station (LGS),
Units 1 and 2 was performed during the period of May 11 through May 15, 2009. Based on the
audit, the NRC staff concludes that: (1) LGS had implemented NRC commitments on a timely
basis; and (2) LGS had implemented an effective program for managing !\IRC commitment
changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, ,/'7.
£aA~
Peter Bamford, Project Manager
Plant Licensing Branch 1-2
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket Nos. 50-352 and 50-353
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
REGULATORY COMMITMENTS MADE BY EXELON GENERATION COMPANY, LLC TO
THE NUCLEAR REGULATORY COMMISSION
FOR LIMERICK GENERATING STATION, UNITS 1 AND 2
DOCKET NOS. 50-352 AND 50-353
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 (Agencywide Documents
Access and Management System (ADAMS) Accession No. ML003741774), the Nuclear
Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI)
document I\IEI99-04, "Guidelines for Managing NRC Commitment Changes" (ADAMS
Accession No. ML003680088) 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.).
2.0 AUDIT PROCEDURE AND RESULTS
An audit of the commitment management program for Limerick Generating Station (LGS), Units
1 and 2 was performed during the period of May 11 through May 15, 2009. The audit was
performed at LGS using documentation provided by Exelon Generating Company, LLC (Exelon)
personnel, as requested by the NRC staff.
Enclosure
-2
The NRC staff reviewed commitments made during the period approximately 3 years prior to the
audit. 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.
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.). Before the audit, the NRC staff searched ADAMS for licensee commitments
associated with LGS for verification. The review included licensing actions and licensing
activities with NRC issuance dates in 2006, 2007, 2008 and portions of 2009. The commitments
included in the review are shown in Table 1.
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 (TSs), and
Updated Final Safety Analysis Reports (UFSARs). 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 provides the specific details and results of the audit for verification of the licensee's
implementation of commitments. All commitments associated with licensing actions or licensing
activities were verified to be completed or adequately tracked by the licensee for future
completion at an appropriate date.
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
- 3
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 LGS is contained in licensee
procedure LS-AA-11 0, Revision 6, "Commitment Management."
The audit reviewed a sample of commitment changes as shown in Table 2, 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 LS-AA-11 0, Revision 6, against NEI 99-04.
Section 6.1 of the procedure lists NEI 99-04 as a reference. The NRC staff found that
LS-AA-110 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. The NRC staff
concludes that the procedure used by the licensee to manage commitments provides the
necessary attributes for an effective commitment management program.
Table 2 provides the specific details and results of the audit of commitment changes for LGS.
Areas warranting further discussion are described below.
Attachment 2 to procedure LS-AA-11 0 contains a flowchart that is intended to match up with
Figure A-1 of NEI 99-04. It was noted during the audit that the two flowcharts differ slightly
downstream of the "Yes" answer in decision step 3, "Original Commitment Necessary for
Compliance." None of the commitments reviewed in this audit would have come to a different
conclusion based on the discrepancy, so it was not judged to detract from the commitment
program's effectiveness. No readily apparent reason for the discrepancy was immediately
available, so the licensee entered the issue into the corrective action program for evaluation
(Issue Report AR 00918829).
It was also noted that commitment change evaluation forms sometimes contain multiple
commitments in the original commitment description. The NRC staff noted that this could allow
a decision block to be skipped for such a "sub-commitment." For example, commitment tracking
number T04090 evaluates the deletion of four sub-commitments all relating to an NRC Safety
Evaluation Report (SER) dated June 28, 1994. Since question number 2 on the change form
only contained three answers it appeared that one of the sub-commitments may not have been
fully evaluated. Subsequent to the site review of the commitment program, the licensee
determined that one of the answers applied to two different sub-commitments, though this was
not clearly identified on the form. Since this commitment change was reported to the NRC as
part of the annual report, this example is not consequential or safety significant, however, the
licensee agreed to evaluate the generic implications of the potential to not fully evaluate a sub
commitment (Issue Report AR 00919845).
- 4
Two commitment change forms (T02935, T02462) did not have strong supporting reasons for
the question "Is the changed commitment necessary to minimize recurrence of the adverse
condition." The licensee stated that the reason for answering this question "No" was that the
station's procedure change process would ensure no recurrence. By deleting the commitment,
however, no annotation to the previous events (in this case Licensee Event Reports (LERs>>
would be retained in the procedure, inhibiting such a review within the procedure change
process. Thus, as written, it appears that a "Yes" answer would have been appropriate. It is
probable that there may be other valid reasons not listed on the form to answer "No" to this
question in both cases. For example, commitment change T02662 evaluates the frequency of a
High Pressure Coolant Injection (HPCI) Turbine Stop Valve Balance Chamber adjustment which
is done by procedure M-C-756-014. During the site review, licensee personnel stated that the
preventative maintenance program would systematically evaluate any surveillance frequency
changes. This rationale was not listed on the form. In the second example, commitment
change number T02462, multiple actions from a past LER were evaluated as not necessary to
prevent recurrence because "No changes will be made to the process without complete review."
This justification is superficial and could be strengthened by specifying what step in the
procedure change process will provide this depth of review considering the loss of the
annotation to the deleted commitment. Alternatively, the rationale could be changed to specify
another applicable reason that recurrence is prevented. The licensee wrote Issue Report
AR 00919868 to evaluate this concern, both generically and in these specific cases.
3.0 CONCLUSION
As discussed above, the licensee's procedure used to manage commitments provides the
necessary attributes for an effective commitment management program. Several suggestions
for program improvement were made that the licensee entered into the corrective action
program for evaluation. The NRC staff agrees that this is the proper response to the issues
identified.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
S. Gamble
Principal Contributor: P. Bamford
Date: June 15, 2009
Table 1
Written Commitments - 2006-2009
LGS NRC NRC Issuance Summary of Commitment Licensee
Submittal TAC and Licensee Tracking Implementation
Date No. Number (if applicable) Status
07/27/2007 MD5937, Amendment Update UFSAR to explicitly Complete - verified
MD5938 Nos. 191/152 specify Technical incorporation into
dated Requirements Manual UFSAR Rev. 14,
OS/29/2008 information is treated at the September 2008.
same level as information
presented in the UFSAR for
the purpose of 10 CFR 50.59
evaluations.
10/19/2007 MD7048, Amendment Update UFSAR to specify In progress - UFSAR
MD7049 Nos. 195/156 doubling of Local Power update not due until
dated Range Monitor uncertainty 2010, tracking
10/28/2008 when using increased documentation for
surveillance interval. Licensee inclusion into next
tracking No. T04666. update was verified.
Procedure changes
effective with
amendment
implementation,
procedure NF-AB-120.
04/21/2008 MD8630, Amendment Implement new working hours In progress-
MD8631 Nos. 198/159 requirements specified in implementation
dated 10 CFR 26, subpart I, scheduled for
03/23/2009 concurrently with 10/01/2009.
implementation of TS
amendment to delete
references to Generic Letter
(GL) 82-12. Licensee tracking
No. AR A 1657834.
04/11/2008 MD7841, Generic Letter Complete walkdowns of Unit 2 Complete - verified by
MD7842 2008-01, dated inaccessible piping systems work orders during site
01/11/2008 during spring 2009 refueling audit.
outage (RFO).
Complete evaluations of In-process - due
subject systems within 60 06/15/2009
days following startup from
2009 RFO. Licensee tracking
No. AR A1659520
In-process - due
Submit supplemental
07/12/2009'
response to NRC with results
of completed evaluations
within 90 days of startup from
spring 2009 RFO. Licensee
tracking No. AR A1659520
10/14/2008 MD7841, Generic Letter Install new vents on Complete - verified
MD7842 2008-01, dated HPCI/Core Spray/Residual sample of completed
01/11/2008 Heat Removal systems during w/o's documenting
2009 RFO new vent additions
during audit
Table 2
Changed Commitments
Tracking Source Justification for NRC
Number change/deletion Notification
T00713 Response to Notice of Original GET module superseded Yes
Violation (NOV) 90-13/90-12 by fleet wide lesson plans and
computer based training. Current
Exelon procedures ensure
continued compliance.
T01992 NRC Inspection Report (IR) Motor Operated Valve program Yes
92-80 commitments are covered by
Exelon procedures that
superseded original procedure
with the contained frequencies.
Current Exelon procedures
ensure continued compliance.
T04090 * NRC SER dated June 28, 1. Drift analysis determined that Yes
1994, Amendment Nos. 71/34 drift program is covered by
current corrective action program
2. Technical specifications have
been revised to specify the 18
month surveillance frequency
3. All refueling floor ventilation
radiation monitor recorders have
been replaced.
4. Analysis shows no need for
I 3 millisecond additional margin.
T02578 GL 93-01 Recommended testing from GL is No
not a regulatory requirement.
Required testing per 10 CFR 50
Appendix E, section VI, paragraph
1 is still required by procedure
EP-AA-124, which is subject to
10 CFR 50.54(q) evaluation.
T03877 LER 1-95-08 Suction strainer testing is no No
longer required. NRC was
notified and approved cessation
of suction strainer testing via
safety evaluation dated August
10, 1998.
T03645 LER 1-95-08 Only a portion of this No
commitment, which had multiple
entries was deleted. The deleted
portion was identical to T03877.
The commitment remains open
for safety relief valve tailpipe
monitoring program, which
remains in place.
Table 2
Changed Commitments
Tracking Source Justification for NRC
Number change/deletion Notification
T03950 LER 2-96-003 TS have been changed to delete No
requirement for emergency diesel
generator failure reports, thus the
procedure references to this
I trackinq are no lonqer needed.
T02289 LER 90-11 Match marking is a standard No
I
maintenance practice and is
called for in procedures PMQ
500-128 throuqh PMQ-500-131.
T02462* LER 1-87-015 HPCI turbine stop valve balance No
chamber adjustment is performed
by procedure M-C-756-014.
Procedure review process will
ensure no recurrence.
T02935* LER 87-061 Commitment reflects procedure No
changes made as a result of 1988
exit interview examiner concerns.
Commitment tracking no longer
required because procedure
review process will ensure no
recurrence of condition.
T03891 Letter to NRC dated August This commitment had two parts. No
19, 1996. One part was a duplicate of a
separate tracked, open
commitment (T03941). The
second part reflects a UFSAR
change made in the past that is
no longer applicable after
completion of the spent fuel pool
rerack.
T02950 NRC IR 87-08 & 87-07 The procedure created to resolve No
this observation (not a finding or
violation) from IR 87-07 response,
OT-117, still exists and the
procedure/plant change process
will ensure proper actions are
taken in response to Reactor
Protection System failures. A
second commitment on this form,
review NUREG-0899 to ensure
Procedure Generation Package
incorporates latest
recommendations, was a
completed one-time action.
- Issue Report written, see report for description
OFFICE LPL 1-2/PM LPL 1-2/LA LPL1-2/BC
NAME Pbamford Abaxter Hchernoff
DATE 6/4/09 6/10/09 6/15/09