ML103610353
| ML103610353 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/30/2010 |
| From: | Siva Lingam Plant Licensing Branch II |
| To: | Krich R Tennessee Valley Authority |
| Lingam, S NRR/DORL 415-1564 | |
| References | |
| TAc ME5170, TAC ME5171 | |
| Download: ML103610353 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 30, 2010 Mr. Rodney M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
SEOUOYAH NUCLEAR PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME5170 AND ME5171)
Dear Mr. Krich:
Once every 3 years, the U. S. Nuclear Regulatory Commission (NRC) staff is required to audit a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction L1C-105, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-105, which is publicly available electronically through the Agencywide Documents Access and Management System (ADAMS) at the Electronic Reading Room of the NRC web site (ADAMS Accession Number ML090640415), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI), NEI 99-04, "Guidance for Managing NRC Commitment Changes."
An audit of Sequoyah Nuclear Plant's (SON's) commitment management program was performed at the SON site during the period of December 15-16,2010. The NRC staff concludes, based on the audit that (1) SON has implemented NRC commitments on a timely basis, and (2) SON has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
.~-r" f'~" ~)
Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328
Enclosure:
Audit Report cc w/encl: Distribution via Listserv
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SEOUOYAH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-327 AND 50-328
1.0 INTRODUCTION AND BACKGROUND
The Office of Nuclear Reactor Regulation (NRR) of the U.S. Nuclear Regulatory Commission (NRC) has published NRR Office Instruction L1C-105, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance issued by the Nuclear Energy Institute (NEI) in NEI 99-04, "Guidance for Managing NRC Commitment Changes." The current revision to L1C-105 is publicly available electronically through the Agencywide Documents Access and Management System (ADAMS), at the Electronic Reading Room of the NRC web site (ADAMS Accession Number ML090640415).
According to L1C-105, which cites the definition from NEI-99-04, a "regulatory commitment" is 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. L1C-105 further directs 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 Sequoyah Nuclear Plant's (SON's) commitment management program was performed at SON in Soddy Daisy, TN during the period December 15-16,2010. The audit reviewed commitments made since the previous NRC audit report dated November 7,2007 (ADAMS Accession Number ML072990038). 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 should determine whether they have been captured in an effective program for future implementation.
2.1.1 Audit Scope The audit addressed most of the 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 or licensing activities. Commitments made in Licensee Event Reports Enclosure
- 2 or in response to Notices of Violation may be included in the audit but the review will be limited to verification of restoration of compliance, not the specific methods used.
The NRC staff audited commitments that involved orders, exemptions, responses to generic letters and bulletins, and licensee event reports. During the audit, the NRC staff reviewed documents generated by processes in effect during the scope of the audit, and other documents related to the commitments. 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, 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 Before the audit, the NRC staff searched ADAMS for the licensee's submittals during the last 3 years and selected most of the commitments for verification, however, all the commitments made since October 17,2007, were reviewed during this audit. The licensee provided the documentation to support the NRC staff's audit in each of these commitments. The licensee's documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (e.g., plant procedures, examination records, and/or other plant documentation). The NRC staff found that the licensee's commitment tracking programs had captured the regulatory commitments that had been identified by the NRC staff prior to the audit.
Additionally, the NRC staff reviewed plant procedures that had been revised as a result of commitments made by the licensee to the NRC. The NRC staff found that the procedures had been revised in accordance with the commitments made to the NRC. The attached table summarizes the licensee's commitments that were audited by the NRC staff and the current status of the licensee's commitments.
2.2 Verification of 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 audit reviewed most of the commitment changes that included changes that were or will be reported to the NRC, and changes that were not or
- 3 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.
2.2.1 Audit Results The process used at SON for managing commitments is contained in Nuclear Power Group (NPG) document NPG-SPP-03.3, "NRC Commitment Management." Revision 1 of NPG-SPP 03.3 included the guidance prescribed in NEI 99-04; and it requires SON Nuclear Licensing to identify and track commitments using a process similar to that of NEI 99-04. Appendix C to NPG-SPP-03.3 provides an evaluation process to aid in the decision making process regarding scope changes to a commitment. This process is identical to the guidance provided as figure A 1 in NEI 99-04. Scope changes must be evaluated, and justified by the responsible organization within NPG. Form NPG-SPP-03.3-1 is then forwarded to SON Nuclear Licensing for appropriate notification and tracking.
Additionally, the NRC staff reviewed most of SON's commitments for the period of October 17, 2007 to December 16, 2010. The NRC staff found that the basis/justification provided for the change to each commitment was acceptable; and that the changes were managed effectively, in accordance with plant procedures.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) SON has implemented commitments in a timely basis, or is tracking them for future implementation; and (2) SON has implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Zachary Kitts, SON Site Licensing Engineer Principal Contributor: Siva P. Lingam
Attachment:
Summary of Audit Results
SUMMARY
OF RESULTS AND REGULATORY COMMITMENTS INCLUDED IN AUDIT AT SEQUOYAH NUCLEAR PLANT PERFORMED DURING DECEMBER 15 AND DECEMBER 16, 2010 litem No.
Commitment No.
Commitment LetterlDate Description of Commitment Status Method of Closure 1
NC010172296 SQN-TS-09-02 9/29/09 TVA will include in Steam Generator Tube Inspection Report (SGTIR) any flaws that are identified during the inspection of the clod legs. The SGTIR will report tubes where slippage has occurred and will include any tube where the bottom of the WEXTEX expansion is greater than 2.88 inches below the top of the tubesheet (Commitment No.4).
closed Surveillance Instruction (SI) 2 SI-SXI-068-114.3, Appendix D, 1.0 I and 1.0 J reflected the commitment requirements.
2 NC010172473 SQN-TS-09-02 9/29/09 TVA will revise the Steam Generator Program (SGP) to confirm that the bottom of the cold leg expansion transition for all tubes is below the top of tubesheet and that the bottom of the transition is no more than 2.88 inches from the top of tubesheet. The 2.88 inches accounts for an uncertainty of 0.12 inch. If the WEXTEX expansion is greater than 2.88 inches below the top of the tubesheet, then the examination will be extended into the tubesheet to ensure at least 7.5 inches (plus measurement uncertainty) of non-flawed tube is inspected (Commitment No.1) closed SI 2-SI-SXI-068-114.3, Section 6.2 [9] reflected the commitment requirements.
- 2 Item No.
Commitment No.
Commitment LetterlDate Description of Commitment Status Method of Closure 3
NC010172631 SQN-TS-09-02 9/29/09 TVA will revise the SGP to inspect the +2/
10.5 inches of the cold leg tubesheets in 20 percent of the open tubes in each steam generator. If a crack-like indication is discovered in this area of a steam generator the 100 percent of that steam generator's cold leg tubesheets will be inspected. If the expanded sample identifies a crack-like indication in the +2/-10.5-inches region then 100 percent of the tubesheets in each of the steam generators will be inspected (Commitment No.3).
closed In SI 2-SI-SXI-068-114.3, Section 6.1.C.3.c (3) was added, 6.1.0.3.a and 6.2 [8]
were revised, and 6.1.0.7.b and 6.1.0.7.c were added to reflect the commitment requirements.
4 NC010173263 SQN-TS-09-02 9/29/09 TVA will revise the SGP to require the following assumed leakage methodology: If cold leg indications are not detected (i.e., a 20 percent sample is performed), then in the faulted SG, TVA will assume a total of four top of tubesheet indications exist in the non-examined tubes at the top-of-tubesheet region (i.e., 0.1 inch to 1 inch below WEXTEX Transition) at an assumed leakage of 0.05 gallons per minute (gpm) per tube plus the inservice Row 1 tubes that have had plugs removed will be assumed to leak at 0.00009 gpm. If cold leg indications are detected, then the hot leg W*
methodology will be applied to the cold leg (except 10 percent of the total cumulative quantity of indications in the cold leg region oto 10.5 inches below the top of tubesheet will be assumed in the cold leg region 10.5 to 12 inches and multiplied by 0.0045 gpm).
(Commitment No.2) closed In SI 2-SI-SXI-068-114.3, Appendix F, items U and V were added, Appendix I data sheet was revised, to reflect the commitment requirements.
- 4 Item No.
10 11 12 Commitment No.
NC0070017001 NC0080002001 NC0080021003 I Commitment Letter/Date Description of Commitment Status Method of Closure SQN-TS-06-03 8/14/07 TVA design configuration controls will ensure that the new minimum essential raw cooling water (ERCW) design flow to each emergency diesel generator heat exchanger is at least 400 gallons per minute (including 5 percent measurement uncertainties). The supporting diesel calculation MDQ 000 067 2003 142 will be revised to capture the revised values and Tubular Exchanger Manufacturers Association (TEMA) references.
closed The calculation MDQ 000 067 2003 142 was revised and issued as Revision 3, incorporating TEMA values and references. The calculation includes ERCW minimum flow at 522 gpm at 87F and is greater than 400 gpm plus 5% flow measurement uncertainties.
Probability of TVA will revise SQN's steam generator closed Unit 2 Surveillance Instruction prior cycle program to incorporate the methodology for 2-SI-SXI-068-114.3 associated detection implementation of POPCD as described in with SG tubing lSI and (POPCD) TSC of this submittal. The program augmented inspections was 06-06 01/08/08 revision will be completed within 45 days following NRC approval of the SQN Unit 2 POPCD TS Chance 06-06.
revised adding source note C.28.
GL 2008-01 Complete the detailed walkdowns of SQN closed Completed piping surveys of 06/06/08 inaccessible piping sections of GL 2008-01 subject systems prior to startup after the next refueling outage for each unit (Unit 1 Cycle 16, Unit 2 Cycle 16).
SI and RHR cold leg injection piping inside containment up to the seconadary check valve.
Also completed void volume calculation for suspect piping segments in the SI piping. All measurements reviewed for accuracy and potentially voided segments of a sizable volume.
- 5 Item Commitment I Commitment Description of Commitment Status Method of Closure No.
No.
Letter/Date 13 NC0080021 004 GL 2008-01 06/06/08 Complete evaluations of GL 2008-01 subject systems using results of the detailed walkdowns of inaccessible piping sections and submit supplemental responses to NRC documenting completion of the walkdowns and any impact upon the GL 2008-01 response as a result of completed evaluation within 90 days following startup from the listed refueling outages (Unit 1 Cycle 16, unit 2 Cycle 16).
closed Evaluated void potential volume using walkdown data obtained and spreadsheet calculations (PER 138112 and FE 42912).
14 NC0080021005 GL 2008-01 06/06/08 Complete evaluations of GL 2008-01 subject systems using results of the detailed walkdowns of inaccessible piping sections and submit supplemental responses to NRC documenting completion of the walkdowns and any impact upon the GL 2008-01 response as a result of completed evaluation within 90 days following startup from the listed refueling outages (Unit 1 Cycle 16, unit 2 Cycle 16).
closed Completed data reduction for Unit 1 piping surveys and spreadsheet calculations (PER 138112 and FE 42912).
15 NC0080021006 GL 2008-01 06/06/08 GL 2008-01 adverse conditions discovered at WBN will be entered into the Corrective Action Program and evaluated for applicability at SON due to their design and construction similarities.
closed Talked with WBN personnel and reviewed WBN PER database.
16 NC0081007001 TSC 08-06 Implement SON station procedures requiring the inspection of each ice condenser within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of experiencing a seismic event greater than or equal to an Operating Basis Earthquake (OBE) within the five (5) week period after the completion of ice basket replenishment.
closed Revised Sequoyah Nuclear Plant Abnormal Operating Procedure AOP-N.05, "Earthquake." Added specific guidance regarding the required inspections.
- 6 Item No.
Commitment No.
ICommitment Letter/Date Description of Commitment Status Method of Closure 17 NC0090002001 Confirmatory Order (NRC Office Of Investigation Report No. 2 2007-025) 01/05/09 TVA will ensure that site security procedures for all TVA nuclear sites are revised such that original documents required to be maintained by site security procedures are not destroyed, and are retained in accordance with regulatory requirements.
closed Revised site security procedures at all three sites to comply with the commitment (SON SSI17.1) 18 NC0090002002 Confirmatory Order (NRC Office Of Investigation Report No. 2 2007-025) 01/05/09 As part of first-line supervisory training for security supervisors, TVA will provide fleet-wide training related to Civil Treatment/Ethics, Roles of the Supervisor, Communication in the Workplace, Standards of Conduct, Coaching and Counseling Employees, Operational Issues
& Operating Experience, Leadership, Administration, Client Interface/service, Regulatory reporting requirements, safety, &
Security Observation Program. Upon completion of TVA's transition to an in house security force, TVA will ensure that security supervisors receive training consistent with first-line supervisors in other disciplines.
closed Training completed.
19 NC0090002003 Confirmatory Order (NRC Office Of Investigation Report No. 2 2007-025) 01/05/09 TVA will ensure that security personnel at all TVA nuclear sites receive annual training on the use of TVA's internal programs for resolution of issues/deficiencies (e.g.,
Corrective Action Program, Employee Concerns program), consistent with training received by TVA personnel requiring unescorted access to the TVA nuclear sites.
closed Training completed.
- 7 Item Commitment I Commitment Description of Commitment Status Method of Closure No.
No.
LetterlDate 20 NC0090002004 Confirmatory Order (NRC Office Of Investigation Report No. 2 2007-025) 01/05/09 TVA will conduct a minimum of 15 observations of Sequoyah security activities each month, until TVA transitions to an in house security force.
closed TVA conducted several observations from 1/1/09 to 7/16/09.
21 NC0090002005 Confirmatory Order (NRC Office Of Investigation Report No. 2 2007-025) 01/05/09 During TVA's transition to an in-house security force, each TVA nuclear site will conduct meetings at a minimum of twice each month with the security contractor, to monitor the status of the corrective actions associated with the Security Independent Evaluation.
closed Conducted meeting twice a month during transition.
22 NC0090002006 Confirmatory TVA will assess the effectiveness of the closed Completed on June 30, 2010.
Order (NRC corrective actions and enhancements Verified PERs 146528 and Office Of identified in its Security Independent 208856, and Service Request Investigation Evaluation, and the results of this follow-up 201793.
Report No. 2 assessment will be factored into the TVA 2007-025)
Corrective action Program. TVA agrees to 01/05/09 complete the assessment of the effectiveness of the corrective actions and enhancements no later than June 30, 2010.
23 NC0090002007 Confirmatory Order (NRC Office Of Investigation Report No. 2 2007-025) 01/05/09 Follow-up response to NRC Confirmatory Order (Item h) closed TVA letter dated July 30, 2010, was issued satisfying the NRC Confirmation Order.
- 8 Item No.
Commitment I Commitment No.
LetterlDate Description of Commitment Status Method of Closure 24 NC0090009001 Unit 1 Cycle 16 90-day lSI Summary report with a Relief Request (07/24/09)
SON failed to properly substitute a weld for an inaccessible weld during the Unit 1 Cycle 16 refueling outage. A relief request (RR) is being prepared to request an extension to the first period of the third interval.
closed TVA submitted the RR on August 28, 2009.
25 NC0090003001 GL 2004-02 (02/23/09)
TVA will complete the SON in-vessel downstream effects evaluation following issuance of the final NRC Safety Evaluation report (SER) for Topical Report No. WCAP 16793-NP, "Evaluation of Long-Term Cooling Considering Particulate, Fibrous, and Chemical Debris in the Recirculating Fluid." Following completion of the evaluation the results will be submitted to NRC.
in progress 26 NC0111053319-1 Confirmatory Order (NRC Office Of Investigation Report Nos. 2 2006-025 &2 2009-003) 12/22/09 Through calendar year 2013, TVA shall conduct "Town Hall'-type meetings at least annually at Sequoyah Nuclear plant with TVA and contractor employees which address topics of interest including a discussion on TVA's policy regarding fostering a safety conscious work environment (SCWE). In the event of the transfer of the operating license of a facility to another entity, if any, the commitments for such facility shall survive any transfer of ownership.
closed (part 1)
To resolve NRC Confirmatory Order, TVA generated a commitment dividing into 4 parts. On May 19 and 20, 2010, the Station updates were conducting at Sequoyah by the Site Vice President.
Part of the meetings discussed TVA's and Sequoyah's policy regarding the fostering of a healthy SCWE practice. All employees and contractors were invited and given the opportunity to ask questions.
No significant issues or concerns were raised during these rneetincs.
- 9 Item Commitment I Commitment Description of Commitment Status Method of Closure No.
No.
Letter/Date 27 NC0111053319-2 Confirmatory Through calendar year 2013, TVA shall in progress PERs 212256 and 230725 Order (NRC conduct "Town Hall'-type meetings at least (part 2) keep track of this commitment.
Office Of annually at Sequoyah Nuclear plant with Investigation TVA and contractor employees which Report Nos. 2 address topics of interest including a 2006-025 & 2 discussion on TVA's policy regarding 2009-003) fostering a safety conscious work 12/22/09 environment (SCWE). In the event of the transfer of the operating license of a facility to another entity, if any, the commitments for such facility shall survive any transfer of ownership.
28 NC0111053319-3 Confirmatory Through calendar year 2013, TVA shall in progress PERs 212256 and 230725 Order (NRC conduct "Town Hall'-type meetings at least (part 3) keep track of this commitment.
Office Of annually at Sequoyah Nuclear plant with Investigation TVA and contractor employees which Report Nos. 2 address topics of interest including a 2006-025 & 2 discussion on TVA's policy regarding 2009-003) fostering a safety conscious work 12/22/09 environment (SCWE). In the event of the transfer of the operating license of a facility to another entity, if any, the commitments for such facility shall survive any transfer of ownership.
- 10 Item No.
29 Commitment No.
NC0111053319-4 ICommitment LetterlDate Description of Commitment Status Method of Closure Confirmatory Order (NRC Office Of Investigation Report Nos. 2 2006-025 & 2 2009-003) 12/22/09 Through calendar year 2013, TVA shall conduct "Town Hall'-type meetings at least annually at Sequoyah Nuclear plant with TVA and contractor employees which address topics of interest including a discussion on TVA's policy regarding fostering a safety conscious work environment (SCWE). In the event of the transfer of the operating license of a facility to another entity, if any, the commitments for such facility shall survive any transfer of ownership.
in progress (part 4)
PERs 212256 and 230725 keep track of this commitment.
December 30, 2010 Mr. Rodney M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 SUB~IECT:
SEOUOYAH NUCLEAR PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME5170 AND ME5171)
Dear Mr. Krich:
Once every 3 years, the U. S. Nuclear Regulatory Commission (NRC) staff is required to audit a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction L1C-105, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-1 05, which is publicly available electronically through the Agencywide Documents Access and Management System (ADAMS) at the Electronic Reading Room of the NRC web site (ADAMS Accession Number ML090640415), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI), NEI 99-04, "Guidance for Managing NRC Commitment Changes."
An audit of Sequoyah Nuclear Plant's (SON's) commitment management program was performed at the SON site during the period of December 15-16,2010. The NRC staff concludes, based on the audit that (1) SON has implemented NRC commitments on a timely basis, and (2) SON has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/raj Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328
Enclosure:
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
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SLingam DATE 12/29/2010 12/29/10 12/30/10 12/30/10 OFFICIAL RECORD COpy