ML102450675
| ML102450675 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/23/2010 |
| From: | Hall J Plant Licensing Branch IV |
| To: | Edington R Arizona Public Service Co |
| Gibson, Lauren, NRR/DORL/LPL4, 415-1056 | |
| References | |
| TAC ME4138, TAC ME4139, TAC ME4140 | |
| Download: ML102450675 (12) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 September 23, 2010 Mr. Randall K. Edington Executive Vice President Nuclear/
Chief Nuclear Officer Mail Station 7602 Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-2034 SUB~IECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - AUDIT OF LICENSEE REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NOS. ME4138, ME4139, AND ME4140)
Dear Mr. Edington:
On August 24 and 25, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an audit at the Palo Verde Nuclear Generating Station (Palo Verde), Units 1,2, and 3. This audit examined the Arizona Public Service Company (APS) regulatory commitment management program. The enclosed report documents the audit results, which were discussed on August 25, 2010, with Mr. Ronald Barnes, Director of Nuclear Regulatory Affairs, and other members of your staff.
On July 21, 2000, the NRC issued Regulatory Issue Summary 00-017, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," to inform licensees that the Nuclear Energy Institute (NEI) guidance document, NEI 99-04, "Guidelines for Managing NRC Commitments," describes an acceptable way for licensees to control commitments. The NRC normally conducts an audit of a licensee's regulatory commitment management program every 3 years.
Based on the results of this audit, the NRC concludes that APS has an adequate program to implement and manage regulatory commitments. Details of the audit are provided in the enclosed audit report, including our observations and recommendations.
R. Edington -2 If you have any questions, please contact me at 301-415-4032 or randy.hall@nrc.gov.
Sincerely,
/r'~uJ ~. 7~~
James R. Hall, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530
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 I\JUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION ARIZONA PUBLIC SERVICE COMPANY, ET AL.
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1,2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530
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 whether 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 On August 24 and 25, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an audit at the Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3. This audit examined the Arizona Public Service Company (APS, the licensee) regulatory commitment management program. The audit reviewed commitments made since the previous audit on Enclosure
-2 August 1, 2007. 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 the Agencywide Documents Access and Management System (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 NRC staff found most, but not all, of the selected commitments to be effectively implemented. Using the APS tracking program as a starting point, the NRC staff sought to determine that commitments were implemented in plant procedures, in applicable management systems, or in appropriate engineering packages. Four of the ten commitments selected for audit have been completed. One is accurately captured for implementation in the future. Two of the commitments did not accurately reflect the ongoing nature of the commitments. Another commitment has not yet been fully implemented, though steps have been taken to do so. The attached Audit Summary Table provides details of the audit and its results.
- 3 The ongoing nature of two commitments (RCTSAI 3358726,3358731,3358733,3361268, 33621270, and 33361271 (each unit was given a separate number for each commitment)) was not accurately captured in the licensee's program. These commitments were to provide information and a summary report to the NRC following the installation of weld overlays. These commitments apply to Relief Request 36, which is applicable for the remainder of the current 10-year inservice inspection interval for each of the units (expires in 2017 for Unit 2 and 2018 for Units 1 and 3). The licensee determined that weld overlays were not needed and chose not to install the them during the two refueling outages (Units 1 and 2) that have occurred since the commitment was made. Therefore, no information or summary report was submitted. The licensee's commitment tracking system did not accurately capture that these were ongoing commitments. One of the commitments was recorded as being closed since the weld overlays were not installed. As a result of the audit, the licensee has expanded the description of the commitments in the tracking system to reflect their continuing nature. Therefore, the NRC concluded that this is acceptable.
The NRC observed that commitment (RCTSAI 2826269) concerning NRC Generic Letter 2004 02, "Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors" did not appear to have been fully implemented. It is a commitment, for Unit 3, to update programs and procedures with changes that were identified as needed as the result of another related commitment (RCTSAI 2826263). The licensee identified several procedures and specifications regarding insulation that would need to be updated. The subject procedures (40ST-9ZZ09 and 75RP-9RP25) have been updated; however, the associated licensee-controlled specifications have not yet been updated. An Engineering Design Control document has been written to change the specifications and has been posted against them with a status of "work complete" and an associated date of April 3, 2009. According to the licensee's procedure 81 DP-OCC05, specifications are not updated until there are five Engineering Design Control documents posted against them with a status of "work complete" or "issued." Furthermore, according to the licensee's procedure 84DP-ORM29, users of the specifications are expected to also consider any posted but not yet incorporated Engineering Design Control documents. However, since the changes have not yet actually been incorporated into the specifications (Specification Nos. 13-MN-301, 13-MN-0163, and 13 MN-0169), the NRC staff concludes that this commitment was not fully implemented. The due date for this commitment was December 31,2007. The licensee is aware of these issues. The NRC plans to follow up on these issues and other items related to GL 2004-02 during a future commitment audit.
2.2 Verification of APS'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 Palo Verde is contained in Palo Verde Procedure 93DP-OLC08, "Regulatory Commitment Tracking". The audit reviewed a sample of commitment changes that included changes that were or will 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
-4 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 determined that the licensee's procedure is sufficiently similar to NEI 99-04.
However, the two differences from the NEI 99-04 guidance identified in the previous NRC audit remain. At the time of that audit, the NRC staff determined that those differences were not significant or were adequately compensated for in other ways. One new difference was noted during this commitment audit.
The new difference is that Figure A-1, "Commitment Management Change Process," from NEI 99-04 is not included in the licensee's procedures. This is a visual flowchart of the process described in Figure A-3, which is sufficiently covered by the licensee's procedure. However, the Commitment Management Change Process in NEI 99-04 includes an outcome (answering no to all five decisions steps) that would allow the licensee to change the commitment without any notification to the NRC required. This is not an option using the licensee's procedure. The licensee includes all commitment changes not otherwise reported to the NRC in the annual report as discussed in another endpoint of the flowchart. The NRC concluded that this is an acceptable alternative.
As noted in the most recent previous audit (ADAMS Accession No. ML073030039), Figure A-2 "Safety Significance Assessment" of NEI 99-04 is not explicitly provided. At the time of the last commitment audit, the licensee's alternative process of using Palo Verde Procedure 93DP OLC08 for making safety evaluations using the criteria in 10 CFR 50.92(c)(1) through (3) was found acceptable. Palo Verde Procedure 93DP-OLC08 no longer has the appendices, Band C, which were cited as acceptable alternatives to using Figure A-2 in the previous audit. However, the current version of the procedure does include the same information within the text of the description for Step 2 of Appendix A (page 5). Therefore, the NRC concluded that this is an acceptable alternative.
The other previously identified difference is that Step 5, 'Was the Original Commitment Made to Minimize Recurrence of a Condition Adverse to Quality?," of Section 4.2, "Regulatory Commitments," of NEI 99-04 and the associated Part V (Items 5.1 and 5.2) of Figure A-3, "Commitment Evaluation Summary," of the same document are not explicitly provided in the licensee's procedures. The previous audit stated, "the licensee stated that it considers LER
[Licensee Event Report] to be corrective actions and has been managing LERs via the corrective action program, subject to the Reactor Oversight Process, since the issuance of NEI 99-04." In order to verify that commitments were not being made in LER, the NRC reviewed LERs issued since September 2007 and found no examples where the licensee made commitments in the LER.
The NRC staff concluded that the licensee is following NEI 99-04 guidelines for commitment tracking, commitment changes, and reporting requirements. The staff also found that the traceability of the commitments is an area for additional focus by the licensee. The attached Audit Summary Table provides details of this portion of the audit and its results.
-5 In general, all the information needed to determine whether and how a commitment was implemented did not appear tobe readily available through the commitment tracking system.
The licensee frequently needed to search out more information in order to answer the NRC staff questions. On occasion, this meant consulting a different tracking system. Although the information could be found, the NRC staff questioned the sustainability of a system that relies on tacit knowledge. The licensee wrote a Palo Verde Action Request (PVAR) concerning the issue of sustainability for one of the commitments (2826269, PVAR Number 3520499) selected for the commitment implementation portion of the audit.
The NRC staff concluded that the Commitment Management Program meets the criteria in NEI 99-04. The NRC staff offered the following recommendations for enhancing the commitment management system. The NRC staff suggested that APS ensure that a list of implementing documents, such as procedures, is included in the tracking system for a particular commitment.
This was present for some, but not uniformly for all commitments. Including this list would improve the traceability of a commitment. The NRC staff also suggested that APS ensure that long term commitments with multiple due dates are accurately captured (this recommendation was implemented for the applicable commitments in the implementation audit prior to the audit concluding). Finally, APS should verify that all sub-elements to commitments have been fully implemented or completely incorporated prior to closing the commitment. The licensee acknowledged the NRC suggestions and noted that new employees would likely benefit from better traceability.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that: (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Principal: Fara Oreshack Ronald Barnes Tom Weber l\IIarianne Webb Rusty Stroud Principal Contributor: Lauren Gibson Date: September 23, 2010
Attachment:
Summary of Audit Results
Audit Summary A. Commitment Implementation 3479977 This correspondence documents Arizona Public Letter from licensee, "Commitment The commitment is accurately Service Company's (APS) commitment to incorporate to Incorporate in the Updated Final recorded in the licensee's tracking into the PVNGS [Palo Verde Nuclear Generating Safety Analysis Report (UFSAR) a system. The status is "working." It Station] Updated Final Safety Analysis Report Requirement to Periodically Assess is not yet in its UFSAR, but the due (UFSAR), in the next update required by 10 CFR the Containment Building Interior date to incorporate it has not yet 50.71(e), a requirement to assess the containment Coating System," dated May 7, passed.
building interior coating system in accordance with the 2010 (ADAMS Accession PVNGS Containment Coatings Condition Assessment No. ML101390211).
procedure every operating cycle. This requirement was described in APS letter no. 102-05973, dated March 13,2009, Revision 1 to Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors" (ADAMS Accession No. ML090830334). The next UFSAR update is scheduled to be issued in June 2011.
2826269 Implement in Unit 3 changes to programs and Letter from licensee, "Response to This commitment is not yet fully procedures to ensure and/or enhance the control of Request NO.2 in NRC Generic implemented, although the licensee transportable debris in containment. Due Letter 2004-02... ," dated has recorded it as closed. As the December 31 , 2007. September 1, 2005 (ADAMS result of another commitment Accession No. ML052500306). (RCTSAI2826263), the licensee identified changes to procedures and specifications to make in order to meet this commitment. The changes were incorporated into the procedures but have not yet been incorporated into the specifications.
An Engineering Design Control document has been written and is posted against the specifications.
Attachment
-2 A. Commitment Implementation i ., I 3220643 APS has verified that a hydrogen monitoring system License Amendment Request, Implemented.
capable of diagnosing beyond design-basis accidents dated January 15, 2009 (ADAMS is installed at PVNGS and is making a regulatory Accession No. ML0903502121);
commitment to maintain that capability. The Issuance May 14, 2009 (ADAMS hydrogen monitors will be included in the Technical Accession No. ML091100066).
Requirements Manual (TRM). This regulatory commitment will be implemented within 90 days of issuance of the license amendment.
3306851 Removal of the plant-specific Technical Specification License Amendment Request, Implemented.
requirements will be performed concurrently with the dated May 28, 2009 (ADAMS implementation of the 10 CFR Part 26, Subpart I, Accession No. ML091560229);
requirements. In the event NRC approval for the Issuance September 30, 2009 requested amendment is not obtained before (ADAMS Accession October 1, 2009, the amendment shall be No. ML092710609).
implemented within 30 days of NRC approval and APS shall comply with the new 10 CFR 26, Subpart I, requirements and current Technical Specifications until the approved TS changes are implemented.
3067627 APS will establish the Technical Specification Bases License Amendment Request, Implemented.
for LCO 3.0.8 as adopted with the applicable license November 14, 2007 (ADAMS amendment for snubbers (TSTF-372). Due Date: Accession No. ML073300459);
The TS Bases for LCO 3.0.8 will be implemented Issuance May 30, 2008 (ADAMS along with the TS amendment. Accession No. ML081410225).
Three Security Related Commitments Letter from Licensee, "Supplemental Implemented. One of these Response Regarding commitments was also changed.
Implementation Details for the The change was made in Phase 2 and 3 Mitigation accordance with procedures.
Strategies," dated June 7, 2007 (ADAMS Accession No. ML071630363 (non-public)).
-3 A. Commitment Implementation re, ~~~~~~I ~~~~~~~~~~~~~~~~=
1-3358726; Provide the information delineated in question 9 to the Relief Request Approval, August 7, The licensee has not yet chosen to 2-3358731 ; NRC Project Manager within 14 days after the 2009 (ADAMS Accession No. perform weld overlay installations.
3-3358733 completion of the ultrasonic examination of the weld ML093490344) Therefore, certain commitments are overlay installations. not applicable. The licensee has I 1-3361268; Submit a summary report of the results of the ASME the option of installing the weld 2-3361270; III and ASME XI analyses that demonstrates the full overlays for the remainder of the 3-3361272 structural weld overlay applications will perform their current inservice inspection interval.
intended design function. The report will be submitted The audit found the commitments prior to Mode 4 entry following the outage in which the marked as closed, when in fact no weld overlays are applied. information was given to the NRC Project Manager nor was a summary report submitted. The licensee corrected the status of the commitments to reflect their continuing nature. Also, two of the commitments (3358726 and 3358731) were incorrectly both assigned to Unit 1. The licensee corrected this during the audit.
-4
,------ I B. Change Process I
RCTSAI I Molded case circuit breakers Molded case circuit breakers 2009 Annual Report I According to Procedures 8894 associated with safe-shutdown associated with safe-shutdown ADAMS Accession power sources will be inspected power sources will be inspected on No. ML101530485 and tested on a periodic basis. a periodic basis. All non-single pole molded case breakers will be tested on a periodic basis.
RCTSAI IProvide Preventive Maintenance Provide PM tasks for calibration of 2009 Annual Report According to Procedures 12022 (PM) tasks for calibration of the the class 1E switchgear UV & DIG ADAMS Accession class 1E switchgear UV & DIG protective relays required every two No. ML101530485 protective relays required during (2) years.
each refueling outage.
RCTS IDesign change packages will be Commitment tracking closed. 2009 Annual Report According to Procedures 13226 developed to provide 1E power to Modification installed in Unit 3, the ADAMS Accession containment temperature and modification was canceled for Unit No. ML101530485 humidity detectors, RMS mini 1 and Unit 2.
computer, containment radwaste sump level indication and key radiation monitors that are used in the Diagnostic flow chart. Note that an RCTSAI was apparently never generated for this action. However, this action is being handled as a commitment.
RCTSAI Implement the commitments made Each commercial U.S. PWR unit Letter from Licensee According to Regulatory 2806372 in the Response to Request for shall develop and document a PWR ADAMS Accession CommitmenUAction Change Additional Information Regarding reactor internals aging No. ML101410260 Evaluation Summary, this Steam Generator Replacement and management program within thirty- change was to be reported in Power Uprate License Amendment six months following issuance of the annual report. Instead, it Request [ADAMS Accession MRP-227-Rev. O. was sent in earlier under its No. ML051660184] own separate letter.
- .. ML102450675 OFFICE NRR/LPL4/PM NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NRR/LPL4/PM NAME LGibson JRHall JBurkhardt MMarkley JRHall DATE 9/10/10 9/20/10 9/10/10 9/21/10 9/23/10