ML120250210
| ML120250210 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/31/2012 |
| From: | Wang A Plant Licensing Branch IV |
| To: | Entergy Operations |
| Wang, A B, NRR/DORL/LPLIV, 415-1445 | |
| References | |
| TAC ME6788 | |
| Download: ML120250210 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 January 31, 2012 Vice President, Operations Entergy Operations, Inc.
River Bend Station 5485 U.S. Highway 61 N St. Francisville, LA 70775
SUBJECT:
RIVER BEND STATION, UNIT 1 -AUDIT OF LICENSEE'S REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NO. ME6788)
Dear Sir or 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 conducted of the River Bend Station, Unit 1 (RBS), commitment management program was performed at the plant site during the period August 8-9, 2011. Based on the audit, the NRC staff concludes that Entergy Operations, Inc. (the licensee), has implemented NRC commitments made to the NRC on a timely basis, and has implemented an effective program for managing NRC commitment changes at RBS. The details of the audit are set forth in the enclosed audit report.
-2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan.wang@nrc.gov.
Sincerely, Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-458
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 THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION RIVER BEND STATION, UNIT 1 DOCKET NO. 50-458
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 activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
2.0 AUDIT PROCEDURE AND RESULTS An audit of the River Bend Station, Unit 1 (RBS), commitment management program was performed at the plant during the period August 8-9, 2011, and discussed on August 9, 2011.
with members of the Entergy Operations. Inc. (Entergy, the licensee) staff. The audit reviewed commitments made by Entergy since the previous audit on April 9-10. 2008. which was documented in an audit report dated May 8,2008 (ADAMS Accession No. ML081230393). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC Enclosure
- 2 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 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, 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 attached table lists the commitments selected for this audit.
The licensee provided the documentation necessary to support the NRC staff's audit in each of the samples selected. The documents included summary sheets providing the status of the commitment and the appropriate backup documentation, as needed (i.e., plant procedures, incoming/outgoing records, and/or other plant documentation).
2.2 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
-3 that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
RBS commitments are tracked in accordance with the licensee's Nuclear Management Manual Procedure EN-Ll-110, Revision 4, "Commitment Management Program." The licensee enters commitments made to the NRC using a commitment tracking database called the Licensing Research System (LRS). According to the licensee, the majority of these commitments fall into the category of "One-time Actions." One-time action commitments are loaded into the database, tracked to implementation, and remain in the database for historical reference. Since the system was created, the licensee has entered more than 17,000 licensee-defined commitments. At the time of the audit, the licensee was tracking approximately 6,000 items in the LRS as regulatory commitments of which 26 were designated as "OPEN" actions items.
There also approximately 400 items that are being tracked as "continuing compliance."
The NRC staff reviewed documentation generated by the licensee categorized as commitment changes, generic letter responses, relief requests, and amendments, to assess the implementation of the licensee's procedure EN-Ll-110, including the status of their completion.
After review of the commitments selected for the audit, the NRC staff found that the licensee's commitment tracking program had captured all of the regulatory commitments and that all of the commitments were met or were on schedule.
2.2.1 Change Control Procedure Verification Changes to a commitment are reviewed by Plant Licensing Management and by the organization that made the change to the commitment. Once a change occurs, the originating department should review the revision against the commitment report to determine if the change maintains satisfactory implementation of the commitment. Attachment 9.3 of procedure EN-Ll-110, "Commitment Change Evaluation Process," is flowchart describing the change process. Procedure EN-Ll-110, Attachment 9.4, "Commitment Change Evaluation Form (CCEF)," is used to document the evaluation of commitment changes. The NRC staff found that procedure EN-Ll-110, Attachment 9.4, for handling commitment changes is consistent with the guidance in NEI 99-04.
2.2.2 Procedure Implementation Assessment The NRC staff reviewed documentation generated by the licensee categorized as a commitment change in order to assess the effectiveness and implementation of such changes. The NRC staff found that the licensee had properly addressed each regulatory commitment change selected for this audit and that the licensee had implemented an effective program to manage commitment changes.
2.2.2.1 Commitment Changes Reportable to the NRC The licensee indicated that it reports all commitment changes to the NRC; therefore, this section is not applicable. During this audit the NRC staff reviewed several commitment change evaluation forms. The forms were complete and detailed and provided a sound basis for the change.
-4 2.2.2.2 Traceability of Commitments Although guidance in NEI 99-04 does not specifically address traceability of commitments; LlC-105 states, in part that The PM should confirm that the licensee has integrated the commitment management system with other line organization functions to ensure traceability of a regulatory commitment following its initial implementation In the licensee's procedure EN-Ll-110, Section 5.8, "Implementing Changes to Documents that Contain Commitments," Subsection [6], the licensee provides instances when implementing document changes should be forwarded to Plant licensing. Section 5.8[6] states, that
[t]he procedure implementing a commitment has undergone reformatting thereby relocating the section or paragraph that implements the commitment. The change originator should provide a marked-up commitment report showing the new or revised section(s) or paragraph(s).
When changing documents, the licensee's procedure directs that its staff should review the document being changed against the commitment report. If ownership for implementing a commitment transfers from one department to another, the person who originates the transfer must obtain approval and acceptance of ownership with the new department. Based on input from responsible departments, the plant licensing staff reviews and updates commitment implementation information and incorporates the data into the LRS database.
Based upon the licensee's implementation of the requirements of EN-Ll-110, the NRC staff found that the licensee's commitments were traceable.
2.3 Audit Observations and Suggestions As stated above, the licensee's procedure EN-Ll-11 0 was found to be consistent with NEI 99-04. The NRC staff has made the following observations during the audit.
The NRC staff notes that the LRS is a mature system that has been in use since approximately 1995. The LRS is an Entergy corporate tracking system. The LRS tracks active and retired commitments. It is also used to track other commitments such as obligations by using different deSignations in the LRS so commitments can be sorted by type and due date. To help ensure regulatory commitments dates are met, the licensee stated that it generates a Licensing Status Report (LSR) at the beginning of each week for assigned licensing personnel and the personnel responsible for completing the actions identified. The weekly LSR provides a 2-week preview look-ahead of upcoming actions in the LRS. In addition, occasionally longer term look-aheads are generated to help ensure that regulatory commitments are not missed. Periodic assessments, approximately once per year, are performed to evaluate for the compliance with the requirements of EN-Ll-11 O. Entergy stated that while it changes the focus of the assessment each year, the licensee checks for the consistency of the LRS data entry every assessment. This assures that the process for and entry of regulatory commitments is maintained and accurate. The NRC staff believes that the above processes are important for maintenance of the regulatory commitment tracking process.
-5
3.0 CONCLUSION
Based on the audit. the NRC staff concludes that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for for managing NRC commitment changes.
The audit results were discussed on August 9, 2011, with Joseph Clark and William Fountain.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT J. Clark, W. Fountain and B. Burmeister Principal Contributor: A. Wang Date: January 31, 2012
Attachment:
List of Commitments Included in the Audit
AUDIT OF ENTERGY OPERATIONS. INC.
MANAGEMENT OF REGULATORY COMMITMENTS AT RIVER BEND STATION PERFORMED AUGUST 8 AND 9. 2011 LIST OF COMMITMENTS INCLUDED IN THE AUDIT Technical Specification (TS) change to the TS Minimum Critical Power Ratio and provide information on the impact of the fuel transition on the plant's safety analyses.
2 Generic Letter A-16911 MD7870 5/15/2008 Generic Letter (GL) 2008-01 CLOSED required walkdowns of emergency core cooling system (ECCS) piping segments susceptible to gas accumulation 3 Amendment A-16850 ME0406 1/21/2009 TS change to adopt Technical CLOSED Specification Task Force (TSTF) change travelers TSTF-163, TSTF-222, TSTF-230, and TSTF-306. Entergy will periodically monitor and trend the time it takes for each diesel generator to reach steady state operation 4 Request Relief A-17018 ME1507 5/14/2010 Entergy will complete a self OPEN assessment against the American Society of Mechanical Engineers (ASME) probabilistic risk assessment (PRA) Standard. By letter dated 12/08/2011 Entergy J
informed the NRC staff that this assessment will not be completed until March 31, 2012.
5 Request Relief A-16963 ME1507 6/16/2009 Upon approval of the risk-informed CLOSED inservice inspection (lSI) program, withdraw the request for alternative CEP-ISI-007 6 Amendment P-17038 ME4431 7/22/2010 Entergy will establish the TS CLOSED Bases for Limiting Condition for Operation (LCO) 3.10.1 as adopted in the amendment for TSTF-484.
ATTACHMENT
-2 No. Category CommltmeQt No. TAC..No. tssu$:9ate "
7 Request Relief P-16747 MD0170 3/10/2006 Request IST-2006-1. which CLOSED requested permission to use Paragraph ISTC-5222 of the ASME Operation and Maintenance (OM) Code 2001 Edition through the 2003 Addenda at RBS.
Paragraph ISTC-5222 provides requirements for monitoring check valves using a condition monitoring program. Entergy agreed to describe the plan to achieve 100% implementation of bi-directional testing for valves currently uni-directionally tested.
8 Amendment P-16924 MD93257 7/28/2008 Entergy will establish the TS CLOSED Bases for TS 3.1.3 consistent with TSTF-475.
9 Amendment P-16982 ME4369 11/19/2009 Incorporate the RBS Cyber CLOSED security plan by reference into the RBS Security Plan.
10 Amendment P-16957 ME1206 4/27/2009 The TS have been revised with the CLOSED implementation of the 10 CFR 26.
Subpart I requirements.
11 Emergency Plan P-16989 ME3353 1/28/2010 Entergy will take actions to ensure Change CLOSED basic electrical and instrumentation and controls (I&C) tasks can be performed by Mechanical maintenance personnel during plant emergencies.
12 Decommissioning P-16978 ME0562 8/13/2009 Entergy will initiate plans to Trust Fund CLOSED address decommissioning shortfalls by appropriate filing with rate regulating jurisdictions not later than 12/31/2009.
-2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan.wang@nrc.gov.
Sincerely, IRN Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-458
Enclosure:
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
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DATE 1/27/12 1/26/12 1/31/12 1/31/12 OFFICIAL RECORD COpy