ML092990218
| ML092990218 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/29/2009 |
| From: | David Wright Plant Licensing Branch II |
| To: | Ajluni M Southern Nuclear Operating Co |
| Wright D, NRR/DORL, 301-415 -1864 | |
| References | |
| TAC ME1630, TAC ME1631 | |
| Download: ML092990218 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 29, 2009 Mr. Mark J. Ajluni Manager, Nuclear Licensing Southern Nuclear Operating Company, Inc.
40 Inverness Center Parkway P.O. Box 1295 Birmingham, Alabama 35201
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 - AUDIT OF SOUTHERN NUCLEAR OPERATING COMPANY, INC.'s (SNC),
MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME1630 AND ME1631 )
Dear Mr. Ajluni:
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 the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), commitment management program was performed at the plant site during the period of July 14 -16,2009. The NRC staff concludes, based on the audit, SNC had implemented NRC commitments on a timely basis.
M. Ajluni
- 2 However, the NRC staff also identified that SNC's process to document and manage NRC regulatory commitment changes could better align with the guidance contained in NEI 99-04.
Details of the audit are set forth in the enclosed audit report.
Sincerely, 0u4 t*
Donna N. Wnght, Project anager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366
Enclosure:
Audit Report cc w/encl: Distribution via Listserv
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS EDWIN I. HATCH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366
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 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 Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), commitment management program was performed at the plant site during the period of July 14 -16,2009. The audit reviewed commitments made since the previous audit on March 23, 2006. 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.
Enclosure
- 2 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 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.
(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 attached Audit Summary provides details of the audit and its results.
The NRC staff reviewed documents generated by the licensee for the commitments listed in Table 1. After identification, most commitments were managed through the action item process.
The NRC staff found that SNC was able to identify the regulatory commitments contained within the licensing actions selected for this audit and provided documentation of the status of the commitment implementation.
While the NRC staff's audit of SNC's commitment management program for Hatch did not identify any regulatory commitments that were not satisfied, the NRC staff identified limitations in the process used to manage regulatory commitments. The licensee indicated that it does not enter the commitments until the licensee's request is approved by the NRC staff, such as issuance of an amendment, approval of the relief request, or exemptions, etc. The NRC staff recommends that the licensee enter all commitments into the system when they are submitted to the NRC, and close them either because they have been implemented, withdrawn, or the licensing request was not approved by the NRC. This action would ensure that commitments not yet implemented have been captured in an effective program for future implementation.
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
- 3 managing and changing commitments. 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 process used at Hatch is contained in procedure 00AC-REG-002-0, "Commitment Identification and Tracking System." Although the NRC staff did not identify any major deficiencies in commitments that were modified or deleted, the licensee's procedure did not detail the threshold of when prior NRC approval is needed for making changes (i.e.,
modifications, deletions) to regulatory commitments. The licensee did not have a dedicated record that included changes that were or will be reported to the NRC, nor changes that were not or will not be reported to the NRC. The licensee's procedure did not detail the justification for either path. When determining prior approval and reporting options, the licensee should evaluate the commitments in terms of safety and regulatory significance. For those commitments that are reported to the NRC, the licensee's procedure did not discuss the frequency at which changes are reported (e.g., individually, annually, or with the FSAR update submittals). The licensee stated that they are currently developing a fleet-wide procedure for commitment management, and that the resulting revision to the commitment management process would consider and better align with the guidance in NEI 99-04.
Condition Report 2009109184 was written to document the weaknesses discussed with the licensee regarding the commitment change considerations and the tracking and implementation improvements needed. Planned corrective actions involve a change to the commitment management procedure, 00AC-REG-002, as an interim measure until the SNC fleet procedure can be developed and implemented.
3.0 CONCLUSION
The NRC staff concludes that, based on the above findings, (1) SNC identified the regulatory commitments contained within the licensing actions selected for this audit and was able to document the status of the commitment implementation; (2) SNC's commitment management program could be improved in the area of tracking commitments with future implementation; (3) the NRC staff could not confirm that SNC has established a well-defined process for managing commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT E. Perkins S. Tipps Principal Contributors: D. Wright, NRR J. Arce, NRR
Attachment:
Summary of Audit Results
AUDIT
SUMMARY
Sample Commitments for Hatch 1 & 2 - July 2009 SNC'S Submittal Regulatory Issue Commitment Scheduled Completion Date (Type)
Status 2/17/06 Application for Technical SNC will establish the Technical Specification Bases for 90 days following NRC Closed NL-05-1699 Specification Amendment to LCO 3.0.8 (and renumber existing LCO 3.0.8 to LCO 3.0.9 approval of LAR ML060520069 Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process for VEGP) as adopted with the applicable license amendments for HNP.
8/29/06 Request to Implement an
- 1) Cable spreading room fan logic will be modified to
- 1) 12/31/07 Closed NL-06-1637 Alternative Source Term automatically trip supply and exhaust fans on initiation of ML062490239 pressurization mode in the main control room.
- 2) 5/31/08 ML062490255
- 2) Units 1 and 2 Turbine Building MCCs credited in the analyses will be walked down to validate their seismic characteristics.
(one-time actions) 6/5/07 Application for Technical Plant Hatch will incorporate the revised slow control rod Upon implementation of Closed NL-07-0731 Specification Improvement to acceptance criteria of 7.5 percent into the TS Bases. This the TS change ML071560598 Revise Control Rod Scram Time Testinq Frequency change will be incorporated in accordance with the Bases Control Proqram described in TS section 5.5.14.
(Continuing) 8/14/07 Proposed Modification of the Perform a post-modification inspection prior to RPV Following the modification Closed NL-07-1155 Unit 1 Core Shroud Stabilizer reassembly, including a general post-maintenance visual during the 1RF023 outage ML072280298 Assemblies inspection and recording of the fit of the shroud hardware scheduled for ML072280301 onto the shroud to confirm that there are no interferences at the support locations and that the installation is in accordance with the requirements of the modification drawings and the GE installation specification 26A7163.
This inspection shall include, as a minimum, those inspections described in Section 7.2.1 (items a through f).
February 2008.
Attachment
- 2 10/3/2007 Technical Specifications
- 1) Changes will be made to operational procedures to Before Implementation Closed NL-07-1709 Revision Request to Adopt ensure that before reducing power to the low power setpoint (Continuing)
ML072820527 TSTF-476 Improved BPWS Control Rod Insertion Process (LPSP), operators shall confirm control rod coupling integrity for all rods that are fully withdrawn. Control rods that have not been confirmed coupled and are in intermediate positions must be fully inserted prior to power reduction to the LPSP. If shutdown is required and all rods which are not confirmed coupled cannot be fully inserted prior to the power dropping below the LPSP, then the original standard BPWS must be adhered to.
- 2) Changes will be made to operational procedures to ensure that after power drops below the LPSP, rods may be inserted from notch position 48 to notch position 00 without stopping at intermediate positions. However, it is recommended that control rods be inserted in the same order as specified for the originallstandard BPWS as much as possible. When in the process of shutting down following improved BPWS with the power below the LPSP, no control rod shall be withdrawn unless the control rod pattern is in compliance with standard BPWS requirements.
10/18/07 Request to Implement an Provide alternate safety related power supply to HNP Units 4/3012010 Closed NL-07-0894 Alternative Source Term 1 and 2 TB ventilation exhaust systems with a manual (One-time)
ML072910399 Response to RAI Regarding the Power Sources for the Turbine Building Ventilation System switchover.
2/26/08 Application of a Dissimilar
- 1) SNC will report to the NRC (1) the examination results of
- 1) Within 14 days after Closed NL-08-0280 Metal Weld Full-Structural the weld overlay and (2) a discussion of any repairs to the ultrasonic examination of ML080570570 Weld Overlay overlay material andlor base metal and the reason for repair.
- 2) SNC will report to the NRC the results of the stress analysis report, which will include results showing that the requirements of Subarticles NB-3200 and NB-3600 of the ASME Code,Section III are satisfied. The stress analysis will also include results showing that the requirements of IWB-3000 of the ASME Code,Section XI, are satisfied. The results will show that the postulated crack including its growth in the nozzles would not adversely affect the integrity of the overlaid welds.
weld overlay installations
- 2) Within 90 calendar days of the completion of the refueling outage (one-time)
M. Ajluni
- 2 However, the NRC staff also identified that SNC's process to document and manage NRC regulatory commitment changes could better align with the guidance contained in NEI 99-04.
Details of the audit are set forth in the enclosed audit report.
Sincerely, IRA!
Donna N. Wright, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366
Enclosure:
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
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