ML102420206
| ML102420206 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 09/13/2010 |
| From: | James Kim Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| kim j | |
| References | |
| Download: ML102420206 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 13, 2010 Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 250 Governor Hunt Road Vernon, VT 05354
SUBJECT:
VERMONT YANKEE NUCLEAR POWER STATION - AUDIT OF ENTERGY'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME4209)
Dear Sir or Madam:
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's 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.
The NRC's staff performed an audit of the Vermont Yankee Nuclear Power Station (VY) commitment management program at VY, which is located near Vernon, Vermont, on August 9 through August 10, 2010, and reviewed commitments made by VY in the past 3 years since the previous audit on January 16 and 17, 2007. Details of the audit are set forth in the enclosed audit report.
-2 If you have questions, please contact me at (301) 415-4125.
Sincerely,
~~
'-' l James Kim, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271
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 VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271
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's 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 The NRC's staff performed an audit of the Vermont Yankee Nuclear Power Station (VY) commitment management program at VY, which is located near Vernon, Vermont, on August 9 through August 10, 2010, and reviewed commitments made by Entergy Nuclear Operations, Inc. (Entergy or the licensee) in the past 3 years since the previous audit on January 16 and 17, 2007. Entergy is the licensee for VY. The Entergy commitment management system is described in the Entergy Corporate Procedure EN-L1-110, "Commitment Management Program," Rev. 1, dated December 27, 2007. EN-L1-110 is based on and implements the recommendations of NEI 99-04, "Guidelines for Managing NRC Commitment Changes," Rev. O.
Enclosure
-2 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 in accordance with the NRC guidance and approved plant procedures. 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 Before the audit, the NRC staff searched Agencywide Documents Access and Management System (ADAMS) for a sampling of the licensee's licensing actions dated within the past 3 years, since the previous audit on January 16 and 17, 2007, and selected a representative sample for verification. The attached Table lists the licensee's commitments which were audited.
The list of the selected regulatory commitments for VY was provided to the site licensing group with a request to provide plant documentation used to track each individual commitment. Also, the site personnel were requested to provide status and a copy of the revised documents (plant procedures, Updated Final Safety Analysis Report (UFSAR), Technical Specifications (TSs),
etc.) for verification, if the required actions had already been completed. The regulatory commitments were reviewed against the plant documents to verify if the commitment had been implemented satisfactorily in accordance with the approved plant procedures.
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.
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, TSs, and UFSARs. Fulfillment of these commitments was indicated by the licensee havlnq taken timely action in accordance with the subject requirements.
-3 2.1.2 Audit Results The NRC staff reviewed the commitments listed in the attached Table to ensure that the selected commitments are included in the plant database used to track the commitments and evaluate the status of completion of each commitment. The NRC staff audit of the VY's Commitment Management System (CMS) determined that entries were not created in a timely manner for several commitments in the Table to adequately track the status of commitments.
The condition reports for these commitments were generated and CMS entries have been created.
A general observation was made of a process weakness in meeting implementation dates and entering CMS entries for each docketed site for commitments made at the fleet level. It appears that VY relied on the issuance of a fleet procedure to satisfy the commitment, but issuance date of the procedure exceeded the scheduled commitment date.
The attached Table summarizes what the NRC staff observed as the current status of licensee commitments reviewed during the audit.
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 VY is contained in the Entergy corporate procedure, EN-L1-110, "Commitment Management Program," Rev. 1 dated December 27,2007. 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.
The NRC staff reviewed the licensee's procedure EN-L1-110, "Commitment Management Program," Revision 1, against NEI 99-04 guidelines. In particular, in regards to managing a change or deviation from a previously completed commitment, Section 1.0 specifically states that the procedure is based on and implements the recommendations of NEI 99-04. Section 5.5 of EN-L1-11 0 defines the process for making changes to a commitment. In general, EN-L1-11 0 follows closely the gUidance of NEI-99-04; it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments.
2.2.1 Audit Results The NRC staff found that the licensee had properly addressed all the regulatory commitments selected for this audit. As a result of the review of the licensee's information, as well as information from other sources, the NRC staff found the licensee's reported status of the audited commitments to be acceptable.
- 4 However, the NRC staff noted that in contrary to the licensee's procedure EN-L1-110, Section 5.5, VY changed or deleted a variety of commitments in response to Generic Letter (GL) 2008 01 without using its Commitment Change Process or documenting via a Commitment Change Evaluation Form.
Entergy procedure EN-L1-100, Section 5.5 states, in part, "When changes to commitments are necessary, commitments are changed in accordance with the Commitment Change Process shown in Attachment 9.3 ... Changes to commitments should be documented on a form similar to the Commitment Change Evaluation Form (CCEF) shown in Attachment 9.4."
The commitments related to GL 2008-01 have been revised and updated by the Entergy Letter, "GL 2008-01 Response to Request for Additional Information Vermont Yankee Nuclear Power Station," BVY 09-061, dated October 22,2009, and these commitments are either completed or being tracked.
The attached Table summarizes what the NRC staff observed as the current status of licensee commitments reviewed during the audit.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) the licensee has implemented or is tracking for future implementation its regulatory commitments, but a process weakness was observed in meeting implementation dates and entering CMS entries for each docketed site for commitments made at the fleet level, and (2) the licensee has an effective program to manage changes to regulatory commitment. The resolution of the discrepancy identified for commitments related to GL 2008-01 has been discussed with the licensee's staff and entered into the corrective action program.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT P. Couture
Attachment:
Table, Audit Summary - Audited Written Commitments and Related Information Principal Contributors: J. Kim S. Sloan Date: September 13, 2010
U.S. NUCLEAR REGULATORY COMMISSION REGULATORY COMMITMENT AUDIT FOR VERMONT YANKEE NUCLEAR POWER PLANT COVERING THE PERIOD APRIL 2006-JUNE 2010 Licensee's Scheduled Item Commitment Licensee Submittal (ADAMS NRC Response (TAC Licensee Commitment 1mplementatio No. Type Accession No.) No./ADAMS Accession No.) Implementation Status Tracking No. n Date (if req.)
Vermont Yankee Nuclear The scheduled Power Station - Issuance Of completion date was Amendment Re: Adoption Of exceeded with no record BVY 06-028, 4/22/06, Technical Specification Task of any verbal or written Relocation of LCO 3.6.1 and One-Time Force (TSTF) Change TSTF communication with the 1 A-16952 SR 4.6.1 and Addition of LCO 5/27/07 Action 372, "The Addition Of Limiting NRC. Commitment 3.0.8 Regarding Snubbers Condition For Operation (LCO) changes made lAW EN (ML061170419) 3.0.8 On The Inoperability Of L1-110. The commitment Snubbers" was completed on (MD1664/ML070530159) 9/16/08.
Arkansas Nuclear One, Unit 1, VY relied on the Grand Gulf Nuclear Station, issuance of a fleet Unit 1, Indian Point Nuclear procedure, EN-RP-204, Generating Unit Nos. 2 And 3, "Special Monitoring CNRO-2006-00030, 5/16/06, Pilgrim Nuclear Power Station, Requirements" to satisfy Application to Use Weighting River Bend Station, Unit 1, the commitment, but the Continuing Factors for External Exposure, 2 P-16953 Vermont Yankee Nuclear 12/2/06 procedure was issued Compliance Monitor the Part of the Whole Power Station, And Waterford on 12/18/07 that Body That Receives the Steam Electric Station, Unit 3 resulted in exceeding Highest Dose (ML061430359)
Application To Use Effective the scheduled Dose Equivalent Weighting commitment date.
Factors For External Exposure (MD1744/ML0621201540)
Arkansas Nuclear One, Unit 1, VY relied on the Grand Gulf Nuclear Station, issuance of a fleet Unit 1, Indian Point Nuclear procedure, EN-RP-204, Generating Unit Nos. 2 And 3, "Special Monitoring CNRO-2006-00030, 5/16/06, Pilgrim Nuclear Power Station, Requirements" to satisfy Application to Use Weighting River Bend Station, Unit 1, the commitment, but the Continuing 3 P-16954 Factors for External Exposure, Vermont Yankee Nuclear 12/2/06 procedure was issued Compliance DDE/LDE/SDE Determination Power Station, And Waterford on 12118/07 that (ML061430359) Steam Electric Station, Unit 3 resulted in exceeding Application To Use Effective the scheduled Dose Equivalent Weighting commitment date.
Factors For External Exposure (MD1744/ML0621201540)
Attachment
- 2 Licensee's Scheduled Licensee Commitment Licensee Submittal (ADAMS NRC Response (TAC Item No. Commitment Implementation Implementation Type Accession No.) No./ADAMS Accession No.)
Tracking No. Date (if req.) Status Arkansas Nuclear One, Units 1 Completed.
and 2, Big Rock Point, Grand Gulf Nuclear Station, Unit 1, Indian Point Nuclear Generating Units 1, 2, and 3, CNRO-2008-00030, 9/30/08, Palisades Nuclear Plant, Request for Approval to Use Pilgrim Nuclear Power Station, Prior to Using Privatel Telephone Security One-Time River Bend Station, Unit 1, Privatel For 4 P-16955 Devices to Transmit Action Vermont Yankee Nuclear Offsite SGI Safeguards Information to Power Plant, and Waterford Communications Authorized Personnel Steam Electric Station, Unit 3 (ML082810473)
Use of Privatel Telephone Security Devices for Transmission of Safeguards Information (MD9861 /ML0829006361)
BVY-04-095, 9/14/04, Vermont Completed.
NRC Receipt Of Vermont Yankee Nuclear Power Station Implemented on Yankee Nuclear Power Station Response to NRC Generic 6/15/05 by BVY-05 One-Time Response To Generic Letter 5 A-16950 Letter 2003-01 "Control Room August 23, 2007 067.
Action 2003-01 "Control Room Habitability" Initial Summary Habitability" Actions Report (MB9868/ML0712905620)
BVY-06-032, 4/3/06, Vermont Vermont Yankee Nuclear Completed.
Yankee Nuclear Power Station Power Station - Response to Implemented on Response to Generic Letter Generic Letter (GL) 2006-02 4/14/06 by BVY-06 One-Time 6 A-16951 2006-02, Grid Reliability and "Grid Reliability and the Impact June 2,2006 038.
Action the Impact on Plant Risk and on Plant Risk and the the Operability of Offsite Power Operability of Offsite Power" (ML0610003100) (MD1045/ML0719300120)
BVY-08-071, 10114/08, Completed.
Vermont Yankee Nuclear Vermont Yankee Nine Month Vent installed during Power Station - Closeout of Response to Generic Letter RFO-27.
Generic Letter 2008-01, 2008-01 (ML0829102920), Procedures revised One-Time "Managing Gas Accumulation 7 A-16829 Install vent on HPCI suction January 2010 to include periodic Action in Emergency Core Cooling, piping and revise HPCI venting.
Decay Heat Removal, and applicable procedures to Containment Spray System" include periodic venting of (MD7891/ML0934904860)
HPCI suction piping
-3 Licensee's Scheduled Licensee Item Commitment Licensee Submittal (ADAMS NRC Response (TAC Commitment Implementation 1mplementation No. Type Accession No.) No.lADAMS Accession No.)
Tracking No. Date (if req.) Status BVY-08-071, 10/14/08, Completed.
Vermont Yankee Nine Month Vermont Yankee Nuclear HPCI Discharge Response to Generic Letter Power Station - Closeout of vent de-committed 2008-01 (ML0829102920), Generic Letter 2008-01, in BVY-09-061 A-168301 One-Time Install vent on HPCI discharge "Managing Gas Accumulation dated 10/22/09.
8 RF028 A-16949 Action piping, CS suction piping, RHR in Emergency Core Cooling, suction piping and LPCI Decay Heat Removal, and injection piping and revise Containment Spray System" applicable procedures to (MD7891/ML0934904860) include periodic ventino BVY-08-071, 10/14/08, The commitment Vermont Yankee Nine Month date was exceeded Vermont Yankee Nuclear Response to Generic Letter without following the Power Station - Closeout of 2008-01 (ML0829102920), EN-L1-110 change Generic Letter 2008-01, Develop administrative controls process. The Continuing "Managing Gas Accumulation 9 A-16831 for capturing the results of July 2009 commitment was Compliance in Emergency Core Cooling, venting operations on HPCI, updated in BVY 09 Decay Heat Removal, and CS and RHR systems, entering 061 dated 10/22/09.
Containment Spray System" results into the CAP, evaluating (MD7891 1M L0934904860) operability and trending the results BVY-08-071, 10/14/08, No NRC approved Vermont Yankee Nine Month TSTF has been Response to Generic Letter Vermont Yankee Nuclear Within 90 days published.
2008-01 (ML0829102920), Power Station - Closeout of following NRC Commitment is still Submit to NRC proposed Generic Letter 2008-01, publication of open.
One-Time changes to VY TS based on "Managing Gas Accumulation the Notice of 10 A-16832 Action final, approved version of the in Emergency Core Cooling, Approval of the TSTF traveler for unacceptable Decay Heat Removal, and TSTF Traveler in gas accumulation in ECCS Containment Spray System" the Federal systems, adjusted as needed (MD7891/ML0934904860) Register to account for plant-specific VY desiqn and licensinc basis BVY-09-061, 10/22/09, GL Vermont Yankee Nuclear Completed.
2008-01 Response to Request Power Station - Closeout of for Additional Information Generic Letter 2008-01, One-Time (ML0930304850), Revise "Managing Gas Accumulation 11 P-16908 January 2010 Action existing procedures to capture in Emergency Core Cooling, the results of venting Decay Heat Removal, and operations on HPCI, CS, and Containment Spray System" RHR svstems (MD7891/ML0934904860)
- 4 Licensee's Scheduled Licensee Item Commitment Licensee Submittal (ADAMS NRC Response (TAC Commitment Implementation Implementation No. Type Accession No.) No./ADAMS Accession No.)
Tracking No. Date (if req.) Status BVY-09-061, 10/22/09, GL Completed.
Vermont Yankee Nuclear 2008-01 Response to Request Power Station - Closeout of for Additional Information Generic Letter 2008-01, (ML0930304850), Implement One-Time "Managing Gas Accumulation 12 P-16907 performance based January 2010 Action in Emergency Core Cooling, administrative controls to UT or Decay Heat Removal, and vent HPCI, RHR and CS Containment Spray System" suction piping and CS (MD7891/ML0934904860) discharge piping Decommissioning Funding Completed by BVY Status Report for Vermont 10-1008 submitted ENOC-09-00024, 8/13/09, Yankee Nuclear Power Station to NRC on 1/28/10 One-Time Decommissioning Funding (ME0583/ML093410582) December 31, with documentation 13 A-16879 Action Assurance Plans 2009 supporting the $40 (ML0915505830) million Entergy Corp. Parent Guarantee.
-2 If you have questions, please contact me at (301) 415-4125.
Sincerely, IRAI James Kim, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-271
Enclosure:
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL1-1 RlF RidsNrrDorlLPL 1-1 RidsNrrPMBVaidya (paper copy) RidsNrrLASLittle (paper copy) RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn1 MailCenter S. Meighan, DORLIT A D. Jackson, Region 1/BC D. Spindler, SRI RidsOGCMailCenter ADAMS ACCESSION No'.. ML102420206 OFFICE LPL 1-1/PM LPL 1-1/LA LPL 1-1/BC NAME JKim SLittie NSalqado DATE 9/09/10 9/08/10 9/13/10 Officlal Record Copy