ML111580073
| ML111580073 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/29/2011 |
| From: | Kalyanam N Plant Licensing Branch IV |
| To: | Entergy Operations |
| Kalyanam N, NRR/DLPM, 415-1480 | |
| References | |
| TAC ME5711 | |
| Download: ML111580073 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 29, 2011 Vice President, Operations Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME5711)
Dear Sir/Madam:
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21,2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
An audit of Waterford Steam Electric Station, Unit 3's (Waterford 3's) commitment management program was performed at the plant site on May 11-12, 2011. Based on the audit, the NRC staff concludes that Entergy Operations, Inc. (the licensee), has implemented NRC commitments on a timely basis and has implemented an effective program for managing NRC commitment changes at Waterford 3. The details of the results of the audit, including the NRC staff observations and recommendations, are set forth in the enclosed audit report.
- 2 If you have any questions, I can be contacted at (301) 415-1480 or via e-mail at kaly. kalyanam@nrc.gov.
Sincerely, N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated 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 ENTERGY OPERATIONS, INC.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382
1.0 INTRODUCTION AND BACKGROUND
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21,2000 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the 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, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.).
2.0 AUDIT PROCEDURE AND RESULTS An audit of the Waterford Steam Electric Station, Unit 3 (Waterford 3) commitment management program was performed at the plant site on May 11-12, 2011. The audit reviewed commitments made by Entergy Operations, Inc. (Entergy, the licensee) since the previous audit on July 24 and 25,2008, which was documented in an audit report dated August 14, 2008 (ADAMS Accession No. ML082240088). The audit consisted of two parts: (1) verification of the licensee's implementation of regulatory commitments that have been completed, and (2) verification of the licensee's program for managing changes to regulatory commitments.
Enclosure
- 2 2.1 Verification of Licensee's Implementation of Regulatory Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented those commitments made to the NRC as part of past licensing actions/activities. For commitments that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
2.1.1 Audit Scope The audit addressed a sample of commitments, majority of which were made during the review period of approximately the last 3 years. The audit focused on regulatory commitments made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) and licensing activities (bulletins, generic letters, etc.).
2.1.2 Audit Results Entergy has implemented Corporate Procedure EN-U-11 0, "Commitment Management Program," which identifies the methods and site organization tools for managing development, review, and implementation of station commitments.
The documents furnished by the licensee during the audit included summary sheets providing the status of the commitments and appropriate backup documentation, as needed (Le.,
commitment change evaluation form, plant procedures, examination records, and/or other plant documentation). The NRC staff reviewed the documents and summarized the selected commitments information in the attachment to this audit report.
The NRC staff audit confirmed that the licensee has documented its implementation of regulatory commitments made to the NRC staff as part of past licensing. The NRC staff audit of the licensee's commitment management program for Waterford 3 did not identify any regulatory commitments that were not satisfied or incorporated into its Commitment Management Program for implementation. The licensee's database was found to be well maintained and the commitments selected for this audit were easily traceable in the database. Licensee personnel were able to demonstrate effective use of the commitment management database and provided status tracking to the applicable implementation documents.
Based on the above, the NRC staff concludes that the licensee has implemented the regulatory commitments management program effectively in accordance with UC-105, "Managing Regulatory Commitments Made by Licensees to the NRC," and consistent with NEI 99-04.
The attachment to this audit report contains details of the audit and a summary of the audit results 2.2 Verification of the Licensee's Program for Managing Regulatory Commitment Changes The primary focus of this part of the audit was to verify that the licensee has established administrative controls for satisfying, modifying, or deleting commitments made to the NRC.
- 3 The NRC staff found that the process sets forth the need for identifying, initiating, tracking, and reporting commitments, managing a change or deviation from a previously completed commitment.
2.2.1 Audit Results The NRC staff reviewed Corporate Procedure EN-Ll-110 and its required forms to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.
The NRC staff compared the guidance in the Entergy Corporate Procedure EN-U-110 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that EN-Ll-110 was consistent with the NEI guidance for identifying, managing, and closing commitments. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in the Corporate Procedure.
Based on the review of the reports provided by the licensee as described above, queries of the CTS database, and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes in accordance with its site procedure has the deficiencies noted below:
In the "Commitment List," under the columns titled, "Text," "Comments," and "Status," a short description of the corrective action to be taken, general comments, and the status of the commitment are provided chronologically. While the NRC staff audit found that many of these notes contained the author(s) (with initials) and date(s), this was not done in a consistent and uniform manner. Many of the notes lacked the author's identity and the date. The NRC staff views these additions provide a valuable historical background.
The attached Audit Summary (Attachment 2) provides details of this portion of the audit and its results.
- 4
3.0 CONCLUSION
Based on the audit, the NRC staff concludes that (1) Entergy has generally implemented or is tracking for future implementation NRC commitments on a timely basis, and (2) the licensee has implemented an effective program to manage regulatory commitment changes, in accordance with LlC-105 and consistent with NEI 99-04.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT W. Steelman M. Mason J. Williams J. Pollock Principal Contributor:
N. Kalyanam Date: August 29, 2Q11
Attachment:
Summary of Audit Results
Summary of Regulatory Commitment Audit Results Performed on May 11-12, 2011 Waterford Steam Electric Station, Unit 3 Entergy Operations, Inc.
Docket No. 50-382 Date of Licensee's TAC No.
Letter ME3421 212212010 ME2464 10/1912009 Commitment ADAMS Documents Accession No.
No.
Description Reviewed Comments, if any ML100550463 A-27419) SI-4052A(8) will be procured as a Safety Class 1 and The NRC staff did not accept the Seismic Category 1 with a similar code edition as scheduled completion dates of the SI-405A(8). The new bypass line will be procured commitments, "Prior to Refuel 17, and installed as Safety Related, ASME [American return to Mode 4," and stated that Society of Mechanical Engineers] Section III, Class 1 it would approve the License up to and including solenoid valve SI-4052A(8).
Amendment Request only after A-27420 A code reconciliation will be performed for any evidence of meeting the components procured to different code edition than commitments. Entergy provided described above.
the requested information through the following letters:
A-27421 SI-4052A(8) seismic qualification will meet the requirements of FSAR [Final Safety Analyses Report]
- 6/812010 (ML101620417).
Section 3.9C and the new valves will be added to FSAR Table 3.9-9 and 3.9C-1.
- 8/12/2010 (ML102300177).
A-27422 SI-4052A(8) will be procured to withstand the environmental and accident conditions inside
- 1/14/2011 (ML110070026).
containment as shown in FSAR Table 3.11-1.
- 3n12011 (ML110670210).
A-27423 SI-4052A(8) will be included in Technical EC-14765 Requirements [Manual (TRM)] Table 3.6-2 (Containment Isolation Valves) similar to SI-405A(8) to demonstrate compliance with GDC [General Design Criterion] 55(a).
A-27425 Seismic qualifications for the controls will meet IEEE
[Institute of Electrical and Electronics Engineers]
344-1975 requirements.
ML092940242 A-27304 Upon NRC approval ofthe proposed TS [Technical EC-22790 Upon receipt of Amendment 225 Specification] change, Entergy will relocate the on 3/18/2010, the change was Waterford 3 Steam Generator Level - High trip implemented.
function to the Waterford Technical Requirements Manual within 90 days of NRC approval.
Status and Date Closed 5/11/2011 Closed 5/11/2011 Closed 5/11/2011 Closed 511112011 Closed 5/1012011 Closed 5/1112011 Satisfied 7/612010 Attachment
- 2 Date of Commitment Licensee's ADAMS Documents Status and TAC No.
letter Accession No.
No.
Description Reviewed Comments, if any Date MD5966 7/3/2007 ML071870125 A-27205 The details of the diesel fuel oil testing program, EC-10752 TS 6.5.13 Diesel Fuel Oil Testing Closed including the acceptance criteria for the parameters Program which includes sampling 111312008 that are included in the sample results, will be and testing requirements, and maintained in site procedures that are reviewed in acceptance criteria, all in accordance with 10 CFR 50.59.
accordance with applicable American Society for Testing and Materials (ASTM) Standards was added.
ME3128 9/18/2008 ML082660038 A-27195 Entergy will establish the Technical Specification (TS)
LO-LAR-2008 Upon receipt of Amendment 219 Closed Bases for Limiting Condition for Operation (LCO) 00216 on 5/1/2009, within 60 days it was 6/3012008 3.0.8 as adopted with the applicable license implemented.
amendment.
A-27196 Entergy will ensure, during the relocation of the LO-LAR-2008 TRM change includes relocation of Closed TS 3.7.8 snubber requirements to the Technical 00216 snubbers and identification of 6/30/2009 Requirements Manual, that the TRM Actions are snubbers required for seismic only.
modified, in accordance with 10 CFR 50.59, to require a record of the design function of the inoperable snubber (i.e., seismic vs. non-seismic),
implementation of any Tier 2 restrictions each time a required snubber is rendered inoperable and the associated plant configuration.
A-27197 Entergy will revise plant procedures or administrative 10 CFR 50.59 LO-LAR-2008-00216, CA Closed process to ensure seismic risks are considered during review for the (Corrective Action) 9 concludes 6/30/2009 application of the LCO 3.0.8 delay period when one or TRM that no procedure changes are more snubbers are inoperable.
needed.
f----....
.....~
MD9671 9/1812008 ML082660040 A-27198 Entergy will extend the second 10-year inservice LO-WTWF RF 19 is currently scheduled to Open inspection interval from 10 years to 20 years for the 2009-0029 start in spring 2014. Also, the due Examination Category 8-A and 8-D reactor vessel date for this commitment set to welds and perform the Waterford 3 inspection in the monitor can be extended as far as 2015 refueling outage plus or minus one refueling RF 21.
cycle.
A-27199 Entergy will perform the second 1 O-year inservice LO-LAR-2008 Since Waterford 3 has been Closed inspection of the Examination Category 8-J welds 00220 approved for risk informed 10m2009 associated with the reactor vessel during the examination as per ASME Code Waterford 3 Fall 2009 refueling outage.
Case N-716, all the category 8-J welds have been reclassified as Category R-A welds inspections do not have to be performed as L.........
per this commitment.
..._c...
- 3 Date of Commitment Licensee's ADAMS Documents Status and Accession No.
No.
Description lAC No.
Letter Reviewed Comments, if any Date A-27279 MD9657 NRC RAI on withdrawing the TS 3/4.3.1 exception of Closed By letter dated 6/30/2009 not requiring adjustment of power indication between (ML091830040), Entergy 7/18/2009 15 percent and 80 percent of Rated Thermal Power withdraws the exception on Core associated with the initial power ascension following a Protection Calculator (CPC) note.
refueling outage.
ME2411 10/1912009 ML092940243 A-27306 The alternative examination proposed by the Relief Closed Request W3-ISI-016 will be performed for LO-LAR-2007 The alternate examinations 2/1112010 proposed by Request for 00206 Waterford 3.
Alternative, W3-ISI-016, is complete. The eddy current examination was performed in accordance with the revised relief request, W3F1-2009-0062 (ML093080128). where the commitment was revised to acquire and analyze ICI ultrasonic data from a minimum of 1.5-inch above the J-groove weld, instead of the originally proposed 1-inch above the J-groove weld.
I
-4 Date of Commitment Licensee's ADAMS Documents Status and lAC No.
Reviewed Comments, if any Letter No.
Description Date ME2401 Accession No.
LO-LAR-2007 The alternate examinations Closed inside diameter and the nozzle tube lower face in 10/19/2009 ML092940241 A-27307 Entergy will perform eddy current examinations of the 00206 proposed by Request for 2/11/2010 Alternative, W3-ISI-016, is by 10 CFR 50.55a(g)(6)(ii)(0). Entergy will also accordance with Code Case N-729-1 as conditioned complete. The eddy current acquire and analyze incore instrumentation (ICI) examination was performed in ultrasonic data from 1 inch above the J-groove weld to accordance with the revised relief the detectable extent of the nozzle tube below the J-request, W3F1-2009-0059 groove weld. (Improvements in data acquisition and (ML093080127), where the analysis that were developed during qualification of commitment was revised to CEOM [control element drive mechanism] volumetric acquire and analyze ICI ultrasonic examinations will be incorporated in the proposed ICI data from a minimum of 1.5-inch examinations).
above the J-groove weld, instead of the originally proposed 1-inch above the J-groove weld.
A-27308 ML050400463 Closed If ultrasonic (TOFO) data is determined to have The alternative examination dated 2/5/2005.
2111/2010 unacceptable quality in the nozzle tube from the root proposed in Relief Request W3 of the J-groove weld to 1 inch below the root of the J ISI-016 for the ICI nozzles was LO-LAR-2007 groove weld, then a manually delivered eddy current performed in accordance with the 00206 examination of the ICI penetration tube 00 [outside revised relief request, W3F1-2009 diameter] surface will be performed.
0059. The ultrasonic data in the area from the root of the J-groove weld to 1 inch below the root of the J-groove weld was acceptable quality. Therefore, the manually delivered eddy current examination of the ICI penetration tube 00 surfacewas not required on any of the ICI nozzles 4/27/2009 With adoption ofTSTF-511, ML091390436 A-27265 Removal of plant-specific TS requirements will be Closed performed concurrently with the implementation of ME1207 Revision 0, "Eliminate Working 10/1/2009 Hour Restrictions from TS 5.2.2 to will be completed no later than October 1, 2009.
10 CFR 26, Subpart I requirements. This commitment Support Compliance with 10 CFR Part 26," the amendment was implemented 10/1/2009.
-5 Date of Commitment ADAMS Licensee's Status afld Documents TACNo.
Accession No.
No.
Letter Description Reviewed Comments, if any
.. Date ME2221 A-27312 9/9/2009 ML092540575 When the Multi-Purpose Canister (MPC) lid is LO-LAR-2010 OPEN connected to the transfer cask lift yoke and the lift 00071 (Due Date yoke extension, if used, designed to ANSI [American 6/30/2011)
National Standards Institute] N14.6 requirements as RF-005-002, specified in the HI-STORM FSAR during handling of Revision 308 the MPC lid over the loaded MPC-32 canister, the slings between the lid and the lifting device shall be constructed of metallic wire rope and meet the requirements of ASME B30.9 and NUREG-0612.
7/22/2010 ML102070092 A-27311 Entergy will upgrade the existing Fuel Handling EC-14270 With the completion of EC-14270, Closed Building (FHB) cask crane main hoist to meet the the FHB crane has been upgraded 5/10/2011 single-failure-proof criteria of NUREG-0554 and to single failure-proof NUREG-0612 as is applicable for the modification of requirements.
the existing non single failure proof crane.
ME4729 11/23/2010 ML103340117 A-27400 Commitment 1: Waterford 3 will replace the fibrous By letter dated 2/9/2011, Entergy Open insulation on the current steam generators with notified the NRC staff the change Reflective Metal Insulation, with a scheduled of the commitment completion completion date of "Prior to Mode 4 after Refueling from refueling outage (RFO) 17 to Outage 17."
RFO 18 in conjunction with the replacement of steam generators.
A-27401 Commitment 2: Revise Emergency Operating OP-902-008 The EOPs OP-902-002 and OP-Closed Procedures to include contingency actions for a Low OP-902-002 5/2/2011 902-008 were revised to carry the Pressure Safety Injection pump failing to trip on contingency actions on 5/2/11.
Recirculation Actuation Signal, with a scheduled Waterford 3 entered Mode 4 on completion date of "Prior to Mode 4 after Refueling 5/8/11.
Outage 17."
ML11 OFFICE NRRIDORLlLPL4/PM NRRIDORLlLPL4/LA NRRIDORLlLPL4/BC NRRIDORLlLPL4/PM NAME NKalyanam JBurkhardt MMarkley NKalyanam DATE 8/24/11 6/8/11 8/26/11 8/29/11