ML111650793
| ML111650793 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/05/2011 |
| From: | Lynnea Wilkins Plant Licensing Branch IV |
| To: | O'Grady B Nebraska Public Power District (NPPD) |
| Wilkins, L E, NRR/DORL/LPL4, 415-1377 | |
| References | |
| TAC ME6055 | |
| Download: ML111650793 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 5, 2011 Mr. Brian J. O'Grady Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - AUDIT OF LICENSEE REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NO. ME6055)
Dear Mr. O'Grady:
An audit of the Cooper Nuclear Station (CNS) commitment management program was performed at plant site on May 3-5, 2011. In the 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.
The NRC staff concludes, based on the audit, that Nebraska Public Power District (the licensee) has implemented NRC commitments on a timely basis, and (2) the licensee has implemented an effective program for managing NRC commitment changes at CNS. The details of the results of the audit are described set forth in the enclosed audit report.
B. O'Grady -2 If you have any questions, please contact me at 301-415-1377 or via e-mail at Iynnea.wilkins@nrc.gov.
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Lynnea E. Wilkins, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
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 NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION DOCKET NO. 50-298
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 commitments are implemented and that changes to the 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 NEt 99-04, and that the 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.). The audit is to be performed every 3 years.
2.0 AUDIT PROCEDURE AND RESULTS An audit of the Cooper Nuclear Station (CNS) commitment management program was performed at plant site on May 3-5, 2011. The audit reviewed commitments made by Nebraska Public Power District (NPPD, the licensee) since the previous audit on December 2-3, 2008, which was documented in an audit report dated December 16, 2008 (ADAMS Accession Enclosure
-2 No. ML083430259). 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. There were a limited number of commitments available for inspection for this audit.
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 those 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 !\IRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in 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, 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 licensee has implemented site-wide Administrative Procedures 0.42, "Regulatory Correspondence Control," and 0.42.1, "Regulatory Commitment Tracking and Commitment Changes," which describes the regulatory commitment management process at NPPD. The process is similar to the guidance provided in NEI 99-04. The procedure includes a consistent process to change NRC regulatory commitments of low safety significance without adversely affecting the level of safety. The process provides a means of identifying commitments (Le., of Administrative Procedure 0.42, List of Regulatory Commitments) and a means for evaluating proposed changes to commitments (Le., Attachment 2 of Administrative
- 3 Procedure 0.42.1, Commitment Change Evaluation). Administrative Procedure 0.42.1 provides administrative controls and responsibilities for the creation, implementation, and maintenance of the Regulatory Commitment/Correspondence Tracking System (RCTS), a database of regulatory requirements and commitments applicable to CNS, including cross-references to the documents or procedures that implement each requirement.
The database and documents furnished by the licensee during the audit provided the status of the commitments and appropriate backup documentation, as needed (e.g., plant procedures, training or examination records, and/or other plant documentation). The NRC staff reviewed the database and documents and summarized the selected commitments information in the attachment to this audit report.
The NRC staff audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.
The process prescribed in Administrative Procedures 0.42 and 0.42.1 provides acceptable tools for the licensee to capture the NRC guidance on commitment management programs. The licensee enters the regulatory commitments made to the NRC into the RCTS database. The regulatory commitments are appropriately coded in the RCTS. Each commitment is numbered and listed. The status of the commitments, implementation dates, target implementation (documents which finally capture the commitment) document information associated with each specific commitment, and comments are captured in the database.
The NRC staff audit of the licensee's commitment management program for CNS did not identify any regulatory commitments that were not met. However, prior to this audit, the licensee identified one missed regulatory commitment. The licensee entered the error into its corrective action program and notified the NRC by letter dated May 7,2009 (ADAMS Accession No. ML091340024). The licensee has maintained the database adequately and the commitments selected for this audit were easily traceable in the database. For commitments that had been completed, the database generally provided an accurate status of the commitment and provided reference to the implementation documentation. No deficiencies were noted.
In general, documents or procedures that are used to fulfill a commitment are changed to reference the commitment. This provides a means to ensure that commitments are neither removed nor changed without management approval in accordance with the plant procedures.
No deficiencies were noted.
Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitments management program adequately and consistent with NEI99-04. The attached Table 1, Audit Summary: Written Commitments and Related Information, contains references to the licensee's commitments selected for review and a summary of the audit results.
-4 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 as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determined whether they have been captured in an effective program for future implementation.
2.2.1 Audit Scope The NRC staff examined commitments made by the licensee prior to the review period that were changed during the review period. 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 NRC audit reviewed a sample of commitment changes to verify that the licensee's commitment management system includes proper notification to the NRC and methods 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 process used at CNS is contained in Administrative Procedures 0.42 and 0.42.1. The primary focus of the audit was to ensure that commitments made to the NRC are implemented and, if changed, the change is made in accordance with the approved plant procedures and with the approval of the plant's management.
2.2.1 Audit Results Detailed processes are provided by which the licensee tracks and implements its regulatory commitments. Any changes to the commitments are processed through Administrative Procedure 0.42.1. Changes to commitments are reported to the NRC in accordance with the guidance of NEI 99-04. The licensee's process identifies the affected commitments, their origin, original criteria, proposed changes, and justification for change. The commitment changes are documented on Commitment Change Evaluation forms. The NRC staff reviewed a sample of changes reported to the NRC in writing, on the docket. Licensee personnel were able to effectively track commitments through the licensee's system through implementing documents.
The attached Table 2, Audit Summary: Modified and/or Deleted Commitments, provides details of this portion of the audit and its results.
Based on the above, the NRC staff concludes that the licensee's program for managing NRC commitments adequately follows the NEI 99-04 guidelines for commitment tracking, commitment changes, and reporting requirements and is, therefore, acceptable.
3.0 CONCLUSION
Based on the results of the audit, the NRC staff concludes that the licensee has implemented an effective program to manage current and future regulatory commitments and regulatory commitment changes in accordance with NEI 99-04. There were no recommendations as a result of this audit.
- 5 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Edward McCutchen LuAnn Bray Principal Contributor: L. Wilkins Date: August 5, 2011
Attachment:
Audit Summary Tables
TABLE 1 Audit Summary: Written Commitments and Related Information Nebraska Public Power District (NPPD)
Cooper Nuclear Station (CNS)
Docket No. 50-298 Item Nuclear Regulatory NPPD Tracking Licensee No. NPPD Reference Document Commission (NRC) Issuance No. Summary of Commitment Implementation Status
- 1. Application dated 6/12/2009 Issuance of Amendment No. NLS2009034 NPPD will establish the Technical Closed. TS bases (ADAMS Accession No. 235 Re: Control Rod Notch Specification (TS) bases changes for changes were issued ML091560032). Testing dated 11/12/2009 TS B3.1.3 consistent with those 12/3/2009 along with TS (ADAMS Accession No. shown in Technical Specification changes per ML092960544). Task Force (TSTF)-475-A, implementation of Revision 1, "Control Rod Notch Amendment No. 235.
Testing Frequency and SRM [Source Range Monitor] Insert Control Rod Action," with the variations noted.
- 2. Letter dated 3/25/2010 Safety Evaluation Report NLS20091 00-01 NPPD will submit (or otherwise make Open. This commitment (ADAMS Accession No. Related to the License available for NRC review and is due to the NRC ML100920090). Renewal of CNS dated approval) a complete proprietary January 18,2012.
9/1/2010 (ADAMS Accession version of an analysis of the core No. ML102000270). plate rim bolts that demonstrates their adequacy considering potential loss of pre-load through the period of extended operation. This will be provided at least 2 years prior to the period of extended operation. NPPD expects to satisfy this commitment using the generic analysis being developed by the Boiling Water Reactor Vessels and Internal Project, provided that it is applicable to CNS.
Attachment
-2 Item Nuclear Regulatory NPPD Tracking Licensee No. NPPD Reference Document Commission (NRC) Issuance No. Summary of Commitment Implementation Status
- 3. Letter dated 2/5/2010 (ADAMS Issuance of Relief Request No. NLS2010076-01 A contact pyrometer will be used Open; however, the Accession No. ML110120540) RI-36, Revision 0, for Fourth to measure the preheat licensee states RI-36 was as supplemented by letter 10-Year Inservice Inspection temperature prior to welding. The subsequently not needed.
dated 8/17/2010 (ADAMS Interval Regarding Weld interpass temperatures will be During the time of the Accession No. ML102350161). Overlay Repair dated measured every three (3) to five audit, the licensee was in 2/18/2011 (ADAMS Accession (5) beads for the first three (3) the process of closing this No. ML110120540). layers and every six (6) to ten commitment.
(10) beads for the remaining layers.
- 4. Letter dated 5/4/2010 (ADAMS Safety Evaluation Report NLS2010050 NPPD will remove sludge and inspect Open. The licensee Accession No. ML101310605). Related to the License the wetted portion of the torus every tracks the completion of Renewal of CNS dated refueling outage from now until the related activities and 9/1/2010 (ADAMS Accession torus is recoated. action items every outage No. ML102000270). via its corrective action system.
- 5. Letter dated 12/21/2009 Safety Evaluation Report NLS20091 00-02 NPPD will confirm that there are no Open.
(ADAMS Accession No. Related to the License niobium-bearing cast austenitic ML102770094). Renewal of CNS dated stainless steel (CASS) materials 9/1/2010 (ADAMS Accession used for vessel internal components, No. ML102000270). or provide a flaw evaluation methodology for niobium-bearing CASS internal components for NRC staff review and approval. This will be provided at least 2 years prior to the period of extended operation.
NPPD expects to implement this commitment by a generic analysis sponsored by the BWRVIP in collaboration with the Electric Power Research Institute.
TABLE 2 Audit Summary: Modified and/or Deleted Commitments Nebraska Public Power District (OPPD)
Cooper Nuclear Station Docket No. 50-298 Licensee Tracking NPPD Change Number Original Commitment Revised Commitment Reporting Document Status NLS2009035-01 NPPD will conduct UT [ultrasonic NPPD will conduct UT, where Letter dated 5/7/2009 Closed. UT Examinations testing] of locations identified in practical, of locations identified in the (ADAMS Accession No. were performed and the CRs [control rooms] to provide CRs to provide additional ML091340024) commitment was closed on additional confirmation that HPCI, confirmation that HPCI, CS, and RHR 7/30/2009.
[high-pressure coolant injection], are operable and to assist in I
CS [containment spray], and RHR determining future vent locations. Note: The licensee missed
[residual heat removal] are Where UT is not practical, an the original commitment date operable and to assist in evaluation will be performed to of 2/27/2009. The licensee determining future vent locations. assess whether potential gas informed the NRC in its accumulation could affect system 5/712009 letter and stated operation. that the error was entered into its corrective action program.
NLS2008081-09 NPPD will revise the fill and vent NPPD will revise the fill and vent Letter dated 3/2/2009 Closed. Commitment was procedures to use UT to provide procedures to use UT to provide (ADAMS Accession No. implemented on 8/3/09 additional assurance the systems additional assurance the systems are ML090650249) are filled. filled.
Completion Date 3/3/09 Completion Date 8/3/09 ---------------
NLS2008081-1 0 NPPD will revise surveillance NPPD will revise surveillance Letter dated 3/2/2009 Closed. Commitment was procedures to use UT to provide procedures to use UT to provide (ADAMS Accession No. implemented on 8/3/09 additional assurance the systems additional assurance the systems are ML090650249) are filled. filled.
Completion Date 3/3/09 Completion Date 8/3/09
ML111650793 WFFIC~ I' NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC I!NAME LWilkins
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