ML11355A097

Audit of Virginia Electric and Power Companys Management of Regulatory Commitments

ML11355A097
Person / Time
Site:	Surry
Issue date:	01/23/2012
From:	Cotton K Plant Licensing Branch II
To:	Heacock D Virginia Electric & Power Co (VEPCO)
Cotton K
References
TAC ME6575, TAC ME6576
Download: ML11355A097 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 23, 2012 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

SURRY POWER STATION, UNIT NOS. 1 AND 2 - AUDIT OF VIRGINIA ELECTRIC AND POWER COMPANY'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME6575 AND ME6576)

Dear Mr. Heacock:

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC [Nuclear Regulatory Commission] 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.

D. Heacock

- 2 On August 9-10, 2011, the NRC staff performed an audit of Virginia Electric and Power Company's (the licensee) commitment management program at Surry Power Station, Unit Nos. 1 and 2. The NRC staff concludes that based on the audit: (1) the licensee had implemented NRC commitments on a timely basis, and (2) the licensee had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

Sincerely, Karen Cotton, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281

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 NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-280 AND 50-281

1.0 INTRODUCTION AND BACKGROUND

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC [Nuclear Regulatory Commission] 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 (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, reliefs, exemptions, etc.)

and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS The regulatory commitment management audit was previously performed at Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2) on July 29, 2008, covering the period of approximately 3 years.

The current audit was performed at Surry 1 and 2 on August 9-10, 2011, verifying the regulatory commitments made by Virginia Electric and Power Company (the licensee) since the previous audit.

The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been implemented 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 (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff searched ADAMS (Agencywide Documents Access and Management System) 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 attached Audit Summary provides details of the audit and its results.

The NRC staff reviewed documents generated by the licensee for the commitments listed in Table 1. After identification, most commitments were managed through the Surry Central Reporting System. The NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of reviewing the licensee's information, as well as information from other sources, the NRC staff found no reason to differ from the licensee's reported status of the audited commitments. Thus, the NRC staff concludes that the procedure used by the licensee to manage commitments is appropriate and effective.

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

- 3 managing and changing commitments. The process used at North Anna Power Station, Unit Nos. 1 and 2 is contained in "Commitment Management," LI-AA-11 0, Revision 0. In general, Revision 0, follows the guidance of NEI-99-04; it sets forth the need for identifying, tracking, and reporting commitments, and it provides a mechanism for changing commitments. 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 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.

3.0 CONCLUSION

The NRC staff concludes that based on the above audit: (1) the licensee had implemented, or is tracking for future implementation, regulatory commitments; and (2) the licensee had implemented an effective program to manage regulatory commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Candee Lovett, Licensing Engineer, Licensing Department, Surry Power Station Principal Contributor: K. Cotton

Attachment:

Summary of Audit Results

Regulatory Commitments Made During the Period from 01/2008 - 212011 Surry Power Station Units 1 and 2 for Audit Item No.

1 Commitments The Surry Power Station, Unit Nos. 1 and 2 (Surry, 1 and 2) Updated Final Safety Analysis Report (UFSAR) revisions will be completed by the end of the spring 2009 Unit 1 refueling outage.

Regarding evaluation of the industry/Nuclear Regulatory Commission (NRC) Technical Specifications Task Force (TSTF) Traveler that will be developed as a follow-up to Generic Letter (GL) 2008-01, the completion date for this corrective action is dependent on the approval of the TSTF. Virginia Electric and Power Company (VEPCO, the licensee), is continuing to support the industry and Nuclear Energy Institute (NEI) Gas Accumulation Management Team activities regarding the resolution of generic technical specification (TS) changes via the TSTF Traveler process.

After NRC approval of the Traveler, VEPCO will evaluate its applicability to Surry 1 and 2 and evaluate adopting the Traveler to either supplement or replace the current TS requirements.

~~~

Letter Serial No.

08-00138 Letter Date 10-14-08 Letter Subject Nine-Month Response to NRC GL 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, And Containment Spray Systems" (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML082890094)

Status OPEN:

Waiting NRC TSTF approval Attachment

-2 Regulatory Commitments Made During the Period from 01/2008 - 212011 Surry Power Station Units 1 and 2 for Audit

---

~-

Commitments Letter Serial Letter Letter Subject Status No.

Item No.

Date

• VEPCO will monitor the results of industry testing and analytical programs related to gas accumulation and pump suction acceptance criteria and determine if any additional changes to any licensing basis documents are required.

The completion date for this corrective action is dependent on the completion of industry testing and analytical programs.

• VEPCO will revise current fill and vent and test procedures as appropriate to assure sufficiently full acceptance criteria, based upon the technical criteria developed for this response, by adding Ultrasonic Testing (UT), venting or other confirmation means at select locations.

These changes will be completed prior to the completion of the Unit 1 spring 2009 refueling outage.

The Pressurizer Safety Valve maintenance 06-30-08 Licensee Event Report (LER) 08-0342 CLOSED 2

50-281/2008-001-00 (ADAMS outage to address aging issues.

strategy will be revised prior to the next refueling Accession No. ML081980059)

Corrective actions for resolution of potential Updated Supplemental 09-002 02-27-09 OPEN:

3 Response to NRC GL 2004-02, chemical and downstream effects on the reactor Waiting on core and flowpaths will be determined and Potential Impact of Debris Westinghouse reported to the NRC within 90 days following the Blockage on Emergency issuance of issuance of revised WCAP-16793-NP and the Recirculation during Design WCAP I

~--

-3 Regulatory Commitments Made During the Period from 01/2008 - 212011 Surry Power Station Units 1 and 2 for Audit Letter Subject Status No.

Letter Commitments Letter Serial Item Date No.

Basis Accidents at Pressurized-Water Reactors ADAMS Accession No. ML090641018 associated NRC Safety Evaluation (SE) Report.

1-------

LAR Measurement Uncertainty CLOSED Surry 2 uncertainty analysis to ensure the 09-223 01-27-10 4

VEPCO will perform the final acceptance of the Recapture (MUR) Power Uprate results are bounded by the statements (ADAMS Accession No.

contained in this License Amendment Request ML100320264)

(LAR) (Attachment 5 Section 1.1.0.4.1). (Prior to operating above 2546 megawatt (MWt)

(98.4% rated power (RP)).)

Technical Requirements Manual (TRM) will be revised to include ultrasonic flow meter (UFM) administrative controls (Attachment 1 Section 3.0). (Prior to operating above 2546 MWt (98.4% RP).)

Revise procedures, programs, and documents for the new UFM (including transducer replacement) (Attachment 5 Section 1.1, 1.1.0.1.1, I.1.H, V11.1, VII.2.A, and VI1.4). (Prior to operating above 2546 MWt (98.4% RP).)

-_Appropriate personnel will receive traininQ on

- 4 Item No.

Regulatory Commitments Made During the Period from 01/2008 212011 Surry Power Station Units 1 and 2 for Audit Commitments Letter Serial Letter Letter Subject No.

Date the UFM and affected procedures (Attachment 5 Sections 1.1.0.1.1, VI1.2.A, VI1.2.0, and VI1.3).

(Prior to operating above 2546 MWt (98.4%

RP).)

• The FAC CHECWORKS SFA models will be updated to reflect the MUR power uprate conditions (Attachment 5 Section IV.1.E.iii).

(Prior to operating above 2546 MWt (98.4%

RP).)

• Simulator changes and validation will be completed (Attachment 5 Section VI1.2.C).

(Prior to operating above 2546 MWt (98.4%

RP).)

• Revise existing plant operating procedures related to temporary operation above full steady-state licensed power levels (Attachment 5 Section VII.4). (Prior to operating above 2546 MWt (98.4% RP).)

• Process UFSAR changes in accordance with Title 10 of the Code of Federal Regulations, (10 CFR) Part 50, Section 50.59 {Attachment 1, Status

-5 Regulatory Commitments Made During the Period from 01/2008 212011 Surry Power Station Units 1 and 2 for Audit I

Item No.

Commitments Letter Serial No.

Letter Date Letter Subject Status Section 3.0). (In accordance with 10 CFR 50.71 (e>>.

• UFM commissioning and calibration will be completed (Attachment 5, Section 1.1.0.2.1).

(Prior to operating above 2546 MWt (98.4%

RP).)

• Confirm flow normalization factors (Attachment 5, Section 1.1.G). (Prior to operating above 2546 MWt (98.4% RP).)

• Rescaling and calibration of main turbine first stage pressure input to anticipated transient without scram (A TWS) mitigation system (AMSAC) (Attachment 5, Sections 11.2.28, VI1.2.B, VII1.2, and VII1.3). (Prior to operating above 2546 MWt (98.4% RP).)

• Determine environmental qualification (EQ) service life for excore detectors (Attachment 5, Sections 1I1.2.A and V.1.C). (Prior to operating above 2546 MWt (98.4% RP).)

• The ex-core neutron detectors are scheduled to

-6 Regulatory Commitments Made During the Period from 01/2008 - 212011 Surry Power Station Units 1 and 2 for Audit Item Letter Subject Status No.

Commitments Letter Serial Letter No.

Date be replaced (Attachment 5,Section V.I.C).

(Unit 1: Fall 2010 Refueling Outage. Unit 2:

Spring 2011 Refueling Outage.)

• Revise emergency operating procedure (EOP) setpoints (Attachment 5, Section VI1.2.A).

(Prior to operating above 2546 MWt (98.4%

RP).)

• The UFM feedwater flow and temperature data will be compared to the feedwater flow venturis output and the feedwater RTD output (Attachment 5, Section 1.1.D.2.1). (Priorto operatinlJ above 2546 MWt (98.4% RP).)

5 Proposed Emergency LAR, CLOSED a commitment to use a 4.7 leakage factor As a conservatism, the proposed change includes09-295 05-05-09 Modified Interim Alternate Repair throughout the period of application of the Criteria for Unit 1 B Steam proposed change.

Generator (SG) Tube Repair (ADAMS Accession No. ML09120444) 6 Proposed LAR, One-Time 09-30-09 CLOSED as part of the SG tube inspection program for 09-4558

• VEPCO commits to monitor for tube slippage Alternate Repair Criteria for SG Unit 1 and Unit 2. (Starting with Unit 2

( supersedes Tube Inspection/Repair for Units Refueling Outage 22 and during subsequent 09-455 and 1 And 2 (ADAMS Accession No.

Unit 1 and Unit 2 SG inspections) 09-455A)

ML09806358)

- 7 Regulatory Commitments Made During the Period from 01/2008 - 212011 Surry Power Station Units 1 and 2 for Audit Letter Subject Status No.

Commitments Letter Serial Letter Item Date No.

• VEPCO commits to periorm a one-time verification of the tube expansion to locate any significant deviations in the distance from the top of tubesheet to the beginning of expansion transition. If any significant deviations are found, the condition will be entered into the plants corrective action program and dispositioned. Additionally, VEPCO commits to notify the NRC of significant deviations. (Prior to the startup following Unit 2 Refueling Outage 22 and Unit 1 Refueling Outage 23)

• VEPCO commits to plug eleven Unit 2 tubes that have been identified as not being expanded within the tubesheet in either the hot leg or cold leg. (During the Unit 2 Refueling Outage 22)

• VEPCO commits to plug three Unit 1 tubes that have been identified as not being expanded within the tubesheet in either the hot leg or cold leg. (During the Unit 1 Refueling Outage 23)

• VEPCO commits to the following: For the

-8 Regulatory Commitments Made During the Period from 01/2008 - 212011 Surry Power Station Units 1 and 2 for Audit Status No.

Letter Subject Item Commitments Letter Serial Letter No.

Date Condition Monitoring assessment, the component of operational leakage from the prior cycle from below the H* distance will be multiplied by a factor of 2.03 and added to the total accident leakage from any other source and compared to the allowable accident induced leakage limit. For the Operational Assessment, the difference between the allowable accident induced leakage and the accident induced leakage from sources other than the tubesheet expansion region will be divided by 2.03 and compared to the observed operational leakage. An administrative operational leakage limit will be established to not exceed the calculated value. (For every operating cycle following Unit 2 Refueling Outage 22 and Unit 1 Refueling OutaQe 23) 7 09-13-10 Revised Reactor Vessel CLOSED retention of irradiated reactor vessel material The Surry UFSAR will be revised to address 09-507A Materials Surveillance Capsule surveillance capsules which do not require testing Withdrawal Schedules - UFSAR to satisfy American Society for Testing and Change (ADAMS Accession No.

Mat~ials (ASTM) E-185.

ML102570804) 8 LER 50-281/2009-001-00 01-28-10 CLOSED Logging Card tests to determine options to reduce Review results of the replaced Supervisory Data 10-055 (ADAMS Accession No.

future failures.

ML112081979)

- 9 Regulatory Commitments Made During the Period from 01/2008 -

Surry Power Station Units 1 and 2 for Audit 212011 Item Commitments No.

9

• The core reload process for Surry Power Station will ensure the Conditions and Limitations of the NRC SE for Optimized ZIRLO, as addressed in Attachment 1, are met when a batch of Optimized ZIRLO is implemented.

• VEPCO will confirm that Westinghouse will provide additional confirmatory data associated with lead test assembly programs at other facilities prior to subsequent cycles of operation with Optimized ZIRLO fuel rod cladding.

10 Upon NRC approval of the TSTF traveler, VEPCO will evaluate it for applicability to Surry 1 and 2. If a license amendment is determined to be necessary, VEPCO will submit a license amendment(s) within one year of NRC approval of the TSTF traveler.

_~ __ L~~

~ __

Letter Serial No.10-074 10-304 Letter Date 02-10-10 06-08-10 Letter Subject LAR for Use of Optimized ZIRLO Fuel Rod Cladding (ADAMS Accession No. ML100470738 Response to Request for Additional Information, GL 2008-01, -"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems" (ADAMS Accession No. ML101600115)

Status CLOSED OPEN:

Waiting on NRC TSTF approval.

D. Heacock

-2 On August 9-10, 2011, the NRC staff performed an audit of Virginia Electric and Power Company's (the licensee) commitment management program at Surry Power Station, Unit Nos. 1 and 2. The NRC staff concludes that based on the audit: (1) the licensee had implemented NRC commitments on a timely basis, and (2) the licensee had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

Sincerely, IRA!

Karen Cotton, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281

Enclosure:

Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:

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