ML102420206
| ML102420206 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| 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 Item No.
Licensee's Commitment Tracking No.
Commitment Type Licensee Submittal (ADAMS Accession No.)
NRC Response (TAC No./ADAMS Accession No.)
Scheduled 1mplementatio n Date (if req.)
Licensee Implementation Status Vermont Yankee Nuclear The scheduled Power Station - Issuance Of completion date was 1
A-16952 One-Time Action BVY 06-028, 4/22/06, Relocation of LCO 3.6.1 and SR 4.6.1 and Addition of LCO 3.0.8 Regarding Snubbers (ML061170419)
Amendment Re: Adoption Of Technical Specification Task Force (TSTF) Change TSTF 372, "The Addition Of Limiting Condition For Operation (LCO) 3.0.8 On The Inoperability Of 5/27/07 exceeded with no record of any verbal or written communication with the NRC. Commitment changes made lAW EN L1-110. The commitment Snubbers" was completed on (MD1664/ML070530159) 9/16/08.
2 P-16953 Continuing Compliance CNRO-2006-00030, 5/16/06, Application to Use Weighting Factors for External Exposure, Monitor the Part of the Whole Body That Receives the Highest Dose (ML061430359)
Arkansas Nuclear One, Unit 1, Grand Gulf Nuclear Station, Unit 1, Indian Point Nuclear Generating Unit Nos. 2 And 3, Pilgrim Nuclear Power Station, River Bend Station, Unit 1, Vermont Yankee Nuclear Power Station, And Waterford Steam Electric Station, Unit 3 Application To Use Effective Dose Equivalent Weighting Factors For External Exposure (MD1744/ML0621201540) 12/2/06 VY relied on the issuance of a fleet procedure, EN-RP-204, "Special Monitoring Requirements" to satisfy the commitment, but the procedure was issued on 12/18/07 that resulted in exceeding the scheduled commitment date.
3 P-16954 Continuing Compliance CNRO-2006-00030, 5/16/06, Application to Use Weighting Factors for External Exposure, DDE/LDE/SDE Determination Arkansas Nuclear One, Unit 1, Grand Gulf Nuclear Station, Unit 1, Indian Point Nuclear Generating Unit Nos. 2 And 3, Pilgrim Nuclear Power Station, River Bend Station, Unit 1, Vermont Yankee Nuclear Power Station, And Waterford 12/2/06 VY relied on the issuance of a fleet procedure, EN-RP-204, "Special Monitoring Requirements" to satisfy the commitment, but the procedure was issued on 12118/07 that (ML061430359)
Steam Electric Station, Unit 3 Application To Use Effective Dose Equivalent Weighting Factors For External Exposure (MD1744/ML0621201540) resulted in exceeding the scheduled commitment date.
Attachment
- 2 Licensee Implementation Status Completed.
Item No.
Licensee's Commitment Tracking No.
Commitment Type Licensee Submittal (ADAMS Accession No.)
NRC Response (TAC No./ADAMS Accession No.)
Scheduled Implementation Date (if req.)
4 P-16955 One-Time Action CNRO-2008-00030, 9/30/08, Request for Approval to Use Privatel Telephone Security Devices to Transmit Safeguards Information to Authorized Personnel (ML082810473)
Arkansas Nuclear One, Units 1 and 2, Big Rock Point, Grand Gulf Nuclear Station, Unit 1, Indian Point Nuclear Generating Units 1, 2, and 3, Palisades Nuclear Plant, Pilgrim Nuclear Power Station, River Bend Station, Unit 1, Vermont Yankee Nuclear Power Plant, and Waterford Steam Electric Station, Unit 3 Use of Privatel Telephone Prior to Using Privatel For Offsite SGI Communications Security Devices for Transmission of Safeguards Information (MD9861 /ML0829006361) 5 A-16950 One-Time Action BVY-04-095, 9/14/04, Vermont Yankee Nuclear Power Station Response to NRC Generic Letter 2003-01 "Control Room Habitability" Initial Summary Actions Report (ML0426103280)
NRC Receipt Of Vermont Yankee Nuclear Power Station Response To Generic Letter 2003-01 "Control Room Habitability" (MB9868/ML0712905620)
August 23, 2007 6
A-16951 One-Time Action BVY-06-032, 4/3/06, Vermont Yankee Nuclear Power Station Response to Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power (ML0610003100)
Vermont Yankee Nuclear Power Station - Response to Generic Letter (GL) 2006-02 "Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power" (MD1045/ML0719300120)
June 2,2006 7
A-16829 One-Time Action BVY-08-071, 10114/08, Vermont Yankee Nine Month Response to Generic Letter 2008-01 (ML0829102920),
Install vent on HPCI suction piping and revise HPCI applicable procedures to include periodic venting of HPCI suction piping Vermont Yankee Nuclear Power Station - Closeout of Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray System" (MD7891/ML0934904860)
January 2010 Completed.
Implemented on 6/15/05 by BVY-05 067.
Completed.
Implemented on 4/14/06 by BVY-06 038.
Completed.
Vent installed during RFO-27.
Procedures revised to include periodic venting.
- 3 Item No.
Licensee's Commitment Tracking No.
Commitment Type Licensee Submittal (ADAMS Accession No.)
NRC Response (TAC No.lADAMS Accession No.)
Scheduled Implementation Date (if req.)
Licensee 1mplementation Status 8
A-168301 A-16949 One-Time Action BVY-08-071, 10/14/08, Vermont Yankee Nine Month Response to Generic Letter 2008-01 (ML0829102920),
Install vent on HPCI discharge piping, CS suction piping, RHR suction piping and LPCI injection piping and revise applicable procedures to include periodic ventino Vermont Yankee Nuclear Power Station - Closeout of Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray System" (MD7891/ML0934904860)
RF028 Completed.
HPCI Discharge vent de-committed in BVY-09-061 dated 10/22/09.
9 A-16831 Continuing Compliance BVY-08-071, 10/14/08, Vermont Yankee Nine Month Response to Generic Letter 2008-01 (ML0829102920),
Develop administrative controls for capturing the results of venting operations on HPCI, CS and RHR systems, entering results into the CAP, evaluating operability and trending the results Vermont Yankee Nuclear Power Station - Closeout of Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray System" (MD7891 1M L0934904860)
July 2009 The commitment date was exceeded without following the EN-L1-110 change process. The commitment was updated in BVY 09 061 dated 10/22/09.
10 A-16832 One-Time Action BVY-08-071, 10/14/08, Vermont Yankee Nine Month Response to Generic Letter 2008-01 (ML0829102920),
Submit to NRC proposed changes to VY TS based on final, approved version of the TSTF traveler for unacceptable gas accumulation in ECCS systems, adjusted as needed to account for plant-specific VY desiqn and licensinc basis Vermont Yankee Nuclear Power Station - Closeout of Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray System" (MD7891/ML0934904860)
Within 90 days following NRC publication of the Notice of Approval of the TSTF Traveler in the Federal Register No NRC approved TSTF has been published.
Commitment is still open.
11 P-16908 One-Time Action BVY-09-061, 10/22/09, GL 2008-01 Response to Request for Additional Information (ML0930304850), Revise existing procedures to capture the results of venting operations on HPCI, CS, and RHR svstems Vermont Yankee Nuclear Power Station - Closeout of Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray System" (MD7891/ML0934904860)
January 2010 Completed.
- 4 Item No.
Licensee's Commitment Tracking No.
Commitment Type Licensee Submittal (ADAMS Accession No.)
NRC Response (TAC No./ADAMS Accession No.)
Scheduled Implementation Date (if req.)
Licensee Implementation Status 12 P-16907 One-Time Action BVY-09-061, 10/22/09, GL 2008-01 Response to Request for Additional Information (ML0930304850), Implement performance based administrative controls to UT or vent HPCI, RHR and CS suction piping and CS discharge piping Vermont Yankee Nuclear Power Station - Closeout of Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray System" (MD7891/ML0934904860)
January 2010 Completed.
13 A-16879 One-Time Action ENOC-09-00024, 8/13/09, Decommissioning Funding Assurance Plans (ML0915505830)
Decommissioning Funding Status Report for Vermont Yankee Nuclear Power Station (ME0583/ML093410582)
December 31, 2009 Completed by BVY 10-1008 submitted to NRC on 1/28/10 with documentation supporting the $40 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:
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RidsRgn1 MailCenter D. Jackson, Region 1/BC RidsOGCMailCenter RidsNrrDorlLPL1-1 RidsOgcRp ADAMS ACCESSION No'.. ML102420206 OFFICE LPL1-1/PM LPL 1-1/LA LPL1-1/BC NAME JKim SLittie NSalqado DATE 9/09/10 9/08/10 9/13/10 Officlal Record Copy