ML092040175
| ML092040175 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 08/05/2009 |
| From: | Tam P Plant Licensing Branch III |
| To: | O'Connor T Northern States Power Co |
| Tam P | |
| References | |
| TAC ME1220 | |
| Download: ML092040175 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August5,2009 Mr. Timothy J. O'Connor Site Vice President Monticello Nuclear Generating Plant Northern States Power Company - Minnesota 2807 West County Road 75 Monticello, MN 55362-9637 SUB"IECT:
MONTICELLO NUCLEAR GENERATING PLANT - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME1220)
Dear Mr. O'Connor:
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 (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 regulatory commitments are being effectively implemented.
An audit of Monticello's commitment management program was performed on site on July 20 and 21,2009, approximately 3 years from the last audit (Agencywide Documents Access and Management System Accession No. ML061280623.) Based on the audit, the "IRC staff concludes that (1) the licensee has implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee had implemented an effective program to manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit report. This completes the NRC staffs efforts on this issue.
Sincerely, -;:;y..
/V"~ja_
~am, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263
Enclosure:
As stated cc: Distribution via ListServ
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
MONTICELLO NUCLEAR GENERATING PLANT (MNGP)
DOCKET NO. 50-263
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 (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 I\\JEI 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 Since the last audit was performed 3 years ago (see audit report dated August 23, 2006; Agencywide Documents Access and Management System Accession No. ML061280623), the NRC staff defined the period covered by this audit to be approximately early 2006, to mid 2009.
The audit was performed onsite at MNGP on July 20 and 21, 2009.
The audit consisted of two major parts: (1) verification of the licensee's implementation of commitments made to NRC that have been completed; and (2) verification of the licensee's program for managing changes to commitments made to NRC.
-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 the bulk of commitments made by the licensee 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, reliefs, etc.) or licensing activities (response to bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation were not included in this audit since those are addressed under the NRC's inspection program. Before the audit, the NRC staff searched the Official Agency Record system for licensee submittals conveying commitments, and have included all the commitments found in the audit (see Table 1). The NRC staff recognizes that "all the commitments" does not equate to "a representative sample"; however, the licensee had not made too many commitments for a "representative sample" to be selected.
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. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
2.1.2 Audit Results The NRC staff reviewed reports generated by the licensee's tracking programs for the commitments listed in Table 1 to evaluate the status of completion. 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 the audit, and that the licensee had implemented the commitments on a timely basis. Table 1 summarizes what the NRC staff observed as the current status of licensee commitments.
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
- 3 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 Monticello are set forth in (1) the licensee's company-wide procedure FG-R-CM-01, "Regulatory Commitment Management,"
Revision 1; and (2) Monticello's procedure 4 AWI-02.09.01, "NRC Commitments," Revision 13.
Both these procedures make extensive references to NEI 99-04. In particular, Section 4.6 of the latter procedure specifically addresses the process to modify or retract existing NRC commitments, citing Figure 5.1 of NEI 99-04 for details of the process. The associated Form 3676, "Regulatory Commitment Change worksheet," instructs the initiator of a commitment to provide needed information and an evaluation of the impacts of a proposed commitment change. Based on review of these two cited documents, the NRC staff concludes that the licensee's procedures follow closely the guidance of NEI-99-04 in that they set forth the need for identifying, tracking, and reporting commitments, and they provide a mechanism for changing commitments.
The effectiveness of a procedure can be indicated by the products that are produced by the procedure. As set forth in Section 2.1.1 and Table 1 of this report, the NRC staff found that the licensee had.properly addressed each regulatory commitment selected for this audit. As a result of review of the licensee's information, the NRC staff found no reason to differ from the licensee's reported status of the audited commitments. Thus, the NRC staff surmises that the procedure used by the licensee to manage commitments is appropriate and effective.
3.0 CONCLUSION
Based on the above audit, the NRC staff concludes that (1) the licensee has implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee has implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Licensee personnel supporting this audit were Rick Loeffler and Ron Baumer.
Principal Contributor: P. S. Tam Date: August 5, 2009
TABLE 1 (page 1 of 3)
MONTICELLO NUCLEAR GENERATING PLANT AUDIT OF WRITTEN LICENSEE COMMITMENTS 2006 THROUGH 2009 NSPM Submittal NRC TAC No.
NRC Issuance Summary of commitment Licensee Implementation Status 09/15/2005 MC8971 Amend. No. 148 In addition to existing requirements to Completed 4/6/2007 L-MT-05-093 (12/07/2006) initiate standby liquid control system when under GAR [General ML052640366 adequate core cooling is not assured, new procedural guidance will be established to initiate the SBLC system on high containment radiation and to note reliance on the SBLC system for pH control.
Assignment Request]
01051583-02.
Commitment No.
M05069A 09/15/2005 MC8971 Amend. No. 148 The Technical Support Guidelines (TSGs)
Completed 4/6/2007 L-MT-05-093 (12/07/2006) will be revised to: (1) add a functional under GAR 01051583 ML052640366 requirement for utilization of SBLC for suppression pool pH control, (2) require manual initiation of the SBLC system in response to a high containment radiation, concurrent with loss of inventory or high drywell pressure, and (3) to continue injection until the SBLC tank low level alarm is received.
03 Commitment No.
M05070A 09/15/2005 MC8971 Amend. No. 148 The procedure changes implemented to Completed 4/6/2007 L-MT-05-093 (12/07/2006) reflect the new SBLC system functional under GAR 01051583 ML052640366 requirement will be included in operator re-qualification training. In addition, appropriate Technical Support Center (TSC) personnel will receive training on the TSG [Technical Support Guideline]
revisions.
04 Commitment No.
M05071A 04/13/2006 MC8971 Amend. No. 148 The control room radiation monitor Completed as TRM L-MT-06-028 (12/07/2006)
Technical Specification surveillances will Section 3.3.7.1, ML061310408 be relocated to the Technical Requirements Manual [TRM] which will be implemented as part of Improved Technical Specifications.
"Control Room Air Intake Radiation - High Instrumentation," Rev.
1 Commitment No.
06030A 06/3012004 MC3692 Amend. No. 143 Will implement a trending program to Completed; EWI L-MT-04-036 and and 144 address setpoints for TS calibration
[Emerging Work ML042040166 MC8972 (09/30/2005 and intervals extended to 24 months. Setpoints Instruction]-08.10.02, 01/12/2006) found to exceed the expected drift for the instruments would require an additional evaluation to ensure the instrument's performance is still enveloped by the assumptions in the drift or setpoint analysis. The trending program will also plot setpoint or transmitter As Found/As-Left (AFAL) values to verify that the performance of the instruments is within expected boundaries and that adverse trends (repeated directional changes in AFAL even of smaller rnaqnitudes) are detected and evaluated.
Rev. 3. contains the commitment and provides the program Commitment No.
M04005A 12/15/2006 L-MT-06-070 MD0302 Amendment 150 (03/09/2007)
Following approval of this license amendment, the USAR emergencv heat Updated USAR Section 10.2.2.3, "Performance
ML063610073 load of 20.0 Million British Thermal Units/
hour (MBTU/hr) will be revised to reflect this new maximum heat load of 24.7' MBTU/hr for the emergency Full Core Offload (FCOL) scenario.
Analysis [reo fuel storage and fuel handling system" via Revision 26 Commitment No M06036A 01/29/2007 MD4095 Amend. No. 151 The LPClioop select time delay relays will Completed 9/18/07 L-MT-07-009 (7/20/2007) be added to the Instrument Trending under GAR 01074682, ML070300053 Program.
9/18/07. Revised procedure EWI 08.10.02 Commitment No.
M07001A 02/27/2007 5 commitments set forth in Enclosure 3 to NA L-MT-07-016 be completed by 12/31/2007 (the 02/27/2007 letter is security-related, thus details of the commitments are not reported here).
09/25/2007 MD6864 Amend. No. 161 The LPCI loop select Recirculation Riser Tracked under GAR L-MT-07-055 (4/7/2009)
Differential Pressure - High function 01113675; due ML072760401 differential pressure indicating switches will be added to the Instrument Trending Program in conjunction with the implementation of this amendment.
10/31/2009.
Commitment No.
M07008A 10/14/2008 MD7847 (1) Complete the detailed walkdowns of Completed 4/15/2009 L-MT-08-063 the applicable inaccessible sections of the under GAR 01134199 ML082880662 Generic Letter 2008-01 subject systems (does not include piping downstream of the low pressure emergency core cooling system outboard injection valves) prior to startup from the 2009 Refueling Outage.
(2) NSPM will complete the evaluations of the applicable inaccessible sections of the Generic Letter 2008-01 subject systems and provide a supplement to the October 2008 response to Generic Letter 2008-01 within 90 days following return to full power from the 2009 Refueling Outage.
(3) NSPM will evaluate the Technical Specification changes in the Technical Specification Task Force Traveler related to gas accumulation within the emergency core cooling system for applicability to Monticello, and submit a license amendment request, adjusted, as needed, to account for the Monticello plant-specific design and licensing basis, within 180 days following NRC publication of the Notice of Availability in the Federal Register.
01 Commitment No.
M08003A Tracked under GAR 01134199-02, due 8/16/2009.
Commitment No.
M08004A Tracked under GAR 01155334-01; will be open long-term Commitment No.
M08011A 02/08/2008 MD8064 Amend. No. 159 (1) The Oscillation Power Range Monitor Tracked under GAR L-MT-08-004 (01/30/2009)
(OPRM) Monitoring Period is projected to 01126901-01; due ML080430622 be from startup following the spring 2009 Refuel Outage to until 90 days of steady-state operation have been achieved after reaching fun-power. The licensee will inform the NRC of any change to the duration of the OPRM Monitoring Period.
9/22/2009 Commitment No.
M08001A
(2) Continue resetting Limiting Safety System Settings (LSSS) setpoints within the specified tolerances (as-left criteria) until the Technical Specification Task Force's TS change pertinent to instrument setpoints [i.e., TSTF-493] has been approved by the NRC and assessed for applicability to Monticello.
(3) Assess applicability of the Technical Specification Task Force's TS change pertinent to instrument setpoints (i.e.,
TSTF-493], when approved by the NRC, to determine whether changes to Monticello's Iicensinq basis are necessary.
Tracked under GAR 01126901-03; due 8/31/2009 Commitment No.
M05060A Tracked under GAR 01126901-02; due 8/31/2009 Commitment No.
M05059A 04/22/2008 MD9489 Amend. No. 158 The licensee will establish and implement Completed 12/1/2008 L-MT-08-012 (11/19/2008)
Technical Specification Bases consistent under GAR 01135394 ML081140388 with the applicable bases discussed in TSTF-475, Revision I,"Control Rod Notch Testing Frequency and SRM [Source Range Monitor] Insert Control Rod Action,"
in conjunction with this amendment.
1 (Technical Specification Bases changed).
Commitment No.
M08008A 04/04/2008 MD9490 Amend. No. 157 (1) The licensee commits to the guidance Completed 6/4/2009 L-MT-08-013 (10/22/2008) within Section 11 of NUMARC 93-01, under GAR 01135167 ML081090628 Revision 2, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"
which provides guidance and details on the assessment and management of risk during maintenance.
(2) The licensee commits to the guidance of NEI 04-08, "Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY (TSTF-427), Industry Implementation Guidance," dated March 2006.
(3) The licensee will revise procedures to ensure that the guidance on the risk assessment and management process described in NEI 04-08 is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.9 are to be applied, in accordance with an overall Configuration Risk Management Program to ensure that potentially risk significant configurations resulting from maintenance and other operational activities are identified and avoided.
01 Commitment No.
M08005A Completed 6/15/2009 under GAR 01135167 02 Commitment No.
M08006A Completed 6/4/2009 under GAR 01135167 03 Commitment No.
M08007A
Mr. Timothy J. O'Connor August5,2009 Site Vice President Monticello Nuclear Generating Plant Northern States Power Company - Minnesota 2807 West County Road 75 Monticello, MN 55362-9637
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME1220)
Dear Mr. O'Connor:
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 (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 regulatory commitments are being effectively implemented.
An audit of Monticello's commitment management program was performed on site on July 20 and 21, 2009, approximately 3 years from the last audit (Agencywide Documents Access and Management System Accession No. ML061280623.) Based on the audit, the NRC staff concludes that (1) the licensee has implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee had implemented an effective program to manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit report. This completes the NRC staff's efforts on this issue.
Sincerely, IRA!
Peter S. Tam, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263
Enclosure:
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PUBLIC LPL3-1 r/f RidsNrrDorlLpl3-1 Resource RidsNrrPMMonticello Resource RidsNrrLABTully Resource RidsRgn3MailCenter Resource ADAMS ACCESSION NUMBER: ML092040175 OFFICE LPL3-1/PM LPL3-1/LA LPL3-1/BC NAME PTam THarris for BTuily LJames DATE 8/3/09 7/31/09 8/5109 OFFICIAL RECORD COpy