ML113540102
| ML113540102 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/29/2011 |
| From: | Joel Wiebe Plant Licensing Branch III |
| To: | Pacilio M Exelon Generation Co |
| Wiebe, Joel NRR/DORL/LPL3-2, 415-6606 | |
| References | |
| TAC ME5300 | |
| Download: ML113540102 (9) | |
Text
REG(J~ UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CLINTON POWER STATION, UNIT NO.1 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME5300)
Dear Mr. Pacilio:
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the 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. In addition, the NRC 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 three 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.
An audit of Clinton Power Station (CPS) Unit No.1 - commitment management program was performed at CPS on December 5 - 6, 2011. The NRC staff concludes, based on the audit, that (1) in general, CPS has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, ~ /'7
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Joel S. Wiebe, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461
Enclosure:
Commitment Management 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 CLINTON POWER STATION, UNIT NO.1 DOCKET NO. 50-461
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 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), the Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes" (ADAMS Accession No. ML003680088), contains acceptable guidance for controlling regulatory commitments. In addition the NRC 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 three 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 (e.g., amendments, reliefs.
exemptions, etc.) and activities (e.g., bulletins, generiC letters, etc.). The audit is to be performed every three years.
2.0 AUDIT PROCEDURE AND RESULTS An audit of Clinton Power Station (CPS) Unit No.1 commitment management programs was performed at CPS on December 5 - December 6, 2011. 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.
Enclosure
-2 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 or licensing activities. 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 NRC staff searched 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 attached Audit Summary provides details of the audit and its resl.Jlts.
The NRC staff reviewed relevant procedures to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC.
The procedures reviewed were: (1) Exelon Nuclear Procedure LS-AA-110, "Commitment Management," Revision 8, and (2) Exelon Nuclear Procedure LS-AA-11 0-1 001, "Commitment Tracking Program T&RM, for Use with PassPort," Revision 6. In addition, the NRC staff reviewed a sample of open and closed commitments to confirm that the licensee has implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation.
The NRC staff compared the guidance in procedures LS-AA-110 and LS-AA-110-1001 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that Exelon Nuclear procedures were consistent with the NEI guidance for identifying, managing, and closing
- 3 commitments. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in the Exelon procedures.
The licensee's commitments are tracked in a computer database called PassPort. Based on reports provided by the licensee and on queries of the PassPort database during the audit, the NRC staff found that PassPort is able to provide the necessary information (e.g., summary of the commitment, commitment type, lead department, responsible individual, due date, extensions, closure method and date, and associated historical information) to effectively manage NRC commitments.
For this part of the audit, the NRC staff reviewed CPS site records associated with commitments involving, generic letters, bulletins, and license amendments to determine whether the licensee had implemented the closed commitments appropriately, and whether the licensee had established a success path for future implementation of the open commitments.
The NRC staff reviewed the documentation associated with the closed regulatory commitments, particularly plant procedures that had been revised as a result of the commitments, and found that, in general, the commitments reviewed had been closed in a manner that fully satisfied the commitments made to the NRC. One instance was identified where a commitment (AR 00828402-03-00) was implemented 5 days later than committed to the NRC. The licensee identified the missed commitment date and documented it in their corrective action program (IR 867053 dated January 15, 2009). Although not required by existing procedures, the NRC staff recommended that, since the NRC staff would have been informed of the change in date if it had been planned and not inadvertent, the licensee should identify the missed commitment date in the next periodic update. The licensee agreed and documented the issue in IR 01301272 dated December 12, 2011.
Based on the sample of commitments reviewed, the NRC staff found that commitments tracked in accordance with procedure LS-AA-11 0, Revision 8, were implemented appropriately. Also, based on the sample of licensee submittals and the NRC staff safety evaluations reviewed, the NRC staff found that commitments were tracked as specified by procedure LS-AA-11 0, Revision 8.
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 by CPS is contained in LS-AA-110, Revision 8. Specifically, Section 4.6 of the procedure states that the commitment change process is consistent with the guidance provided in NEI 99-04. As described in LS-AA-110, if it is determined that a commitment is no longer valid or that there is a better way of implementing the commitment, then the commitment can be changed through the commitment change process. Attachment 1, "Commitment Change Evaluation Form," and Attachment 2, "Decision Making Guidance for Proposed Commitment Changes," of LS-AA-110, provide detailed
-4 instructions regarding making changes to a commitment, including the need to inform the NRC, and contain a data sheet to document the evaluation and approval of changes.
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 attached Audit Summary also provides details of this portion of the audit and its results.
The NRC staff found that procedure LS-AA-11 0, Revision 8 was consistent with the guidance found acceptable in NEI 99-04. The NRC staff found that the licensee followed the process in their procedure.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) CPS has implemented NRC commitments on a timely basis, and (2) CPS has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Ronald Frantz Principal Contributor: Brian Harris Joel Wiebe
Attachment:
Audit Summary
ATTACHMENT
SUMMARY
OF AUDIT RESULTS REGULATORY COMMITMENT AUDIT PERFORMED FROM DECEMBER 5 - 6, 2011 CLINTON POWER STATION, UNIT NO.1
AUDIT
SUMMARY
IMPLEMENTATION OF COMMITMENTS:
The following commitments were chosen for audit and determined to be appropriately implemented, except as indicated:
Regulatory Subject/Description Document(s) Reviewed Commitment Action Tracking Item No.
AR 00565555-01-00 License Amendment (LA) 177 Implementation. Revise
- Technical Bases Document SR 3.1.4.2 Control Rod Scram Time Testing Frequency.
LA 187 - TSTF-423 Change. Modify technical
- AR01245615 specifications to risk-informed requirements regarding AR 00399396-16-00 required action end states.
Generic Letter (GL) 82-12 -Implement Requirements
- LS-AA-119-1001 LA 181 - Commitment for local power range monitor
- ER-AA-300, Revision 6 "Motor Operated AR 00809011-01-00 Valve Program. Valve Program Administrative Procedure" LA 181 - Commitment for LPRM Calibration Extension.
- NF-AB-120, Revision 6
-2 GL 2008 Implement GL 2008-01 Commitments to
- CPS 3312.01, Revision 39d filled.
- IR 867053, dated January 15, 2009
- IR 01301272, dated December 12, 2011 AR 01005316-02-00 LA 190 - Commitment to Revise Spent Fuel Pool Loading Procedures for GE14.
- CPS 1003.10, Revision 6d
- ER-AA-2009, Revision 2
- Work Order #01195711-04, dated July 26, 2010 MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS:
Procedure LS-AA-11 0, Revision 8, was reviewed and found to be consistent with the guidance found acceptable in NEI 99-04.
December 29, 2011 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CLINTON POWER STATION, UNIT NO.1 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME5300)
Dear Mr. Pacilio:
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. In addition, the NRC 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 three 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.
An audit of Clinton Power Station (CPS) Unit No.1 - commitment management program was performed at CPS on December 5 - 6, 2011. The NRC staff concludes, based on the audit, that (1) in general, CPS has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, IRA by N. DiFrancesco forI Joel S. Wiebe, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-461
Enclosure:
Commitment Management Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL3-2 RlF RidsNrrDorlLpl3-2 Resource RidsNrrLASRohrer Resource RidsNrrPMClinton Resource RidsNrrDorlDpr Resource RidsOgcRp Resource RidsRgn3MailCenter Resource ADAMS Accession Number* ML113540102 NRR-106 OFFICE LPL3-2/PM LPL3-21LA LPL3-2/BC LPL3-21PM NAME JWiebe(N SRohrer JZimmerrnan JWiebe(N DiFrancesco IBTullyfor (JWiebe for) DiFrancesco for) for)
DATE 12/29/11 12129111 12/29111 12129/11 OFFICIAL RECORD COpy