ML121140300
| ML121140300 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/30/2012 |
| From: | Peter Bamford Plant Licensing Branch 1 |
| To: | Harden P FirstEnergy Nuclear Operating Co |
| Morgan N, NRR/DORL, 415-1016 | |
| References | |
| TAC ME8133, TAC ME8134 | |
| Download: ML121140300 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 30, 2012 Mr. Paul A Harden Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077 SUBJECT BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS.
ME8133 AND ME8134)
Dear Mr. Harden:
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 those regulatory commitments are being effectively implemented.
An audit of Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) commitment management program was performed on site during the period March 21 - 22,2012. Based on the audit, the NRC staff concludes that FirstEnergy Nuclear Operating Company: (1) 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.
P. Harden - 2 If you have questions or concerns, please contact Nadiyah Morgan at (301) 415-1016.
Sincerely.
~~
Peter Bamford. Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
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 BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412
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, the U. S. 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 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 those 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 An audit of the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2) commitment management program was performed at FirstEnergy Nuclear Operating Company (FENOC) administration building during the period March 21 - 22, 2012. The audit reviewed commitments made since the previous audit on October 28 - 29, 2008. 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 (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). 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. Before the audit, 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., response 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. Ful'fillment 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 found that the FENOC Regulatory Commitment Management Program, NOBP-LP-4004, acceptably implements the NEI-99-04 guidelines, and that the BVPS staff is following the guidance of NOBP-LP-4004.
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 at BVPS-1 and 2 is contained in NOBP-LP 4004. The audit reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The
- 3 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 the FENOC Regulatory Commitment Management Program, NOBP LP-4004, acceptably implements the NEI-99-04 guidelines pertaining to commitment changes.
The BVPS staff is following the guidance of NOBP-LP-4004 in regard to commitment changes.
3.0 CONCLUSION
Based on the above, the NRC staff concludes that: (1) BVPS-1 and 2 has implemented NRC commitments on a timely basis, and (2) BVPS-1 and 2 has implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Kathleen Nevins Principal Contributor: N. Morgan Date: April 30, 2012
Attachment:
Summary of Audit Results
AUDIT
SUMMARY
Submittal Commitment Due Date Documents Status Date Reviewed 3/12/2009 A follow-up supplemental 6/30/2009 - Write-up from Completed response to Generic Letter (GL) commitment on 2004-02 including the results of tracking system 6/30/2009 BVPS-2 debris and chemical (SAP) effects testing (which will include - Response Letter credit for containment dated 6/30/2009 overpressure), results of downstream effects analyses (both in-vessel and ex-vessel), the effects on net positive suction head (NPSH) margins, and details of corrective actions will be submitted to the NRC.
3/25/2009 Removal of the plant-specific 10/1/2009 - Write-up from Completed Technical Specification commitment on requirements will be performed tracking system 9130/2009 concurrently with the - TS 5.2-2 implementation of the 10 CFR - NRC issued Part 26, Subpart I requirements. amendment dated 7/16/2009 4/9/2009 A Metamic surveillance program
- Prior to, or - Write-up from Open will be implemented for the BVPS- current with, commitment 2 spent fuel pool in order to the first fuel tracking system monitor the integrity and offload (FileNet) performance of Metamic. following installation of the Metamic racks and n tree 4/30/2009 Mitigation of the additional fibrous Prior to - Write-up from Completed insulation will be accomplished startup from commitment on through removal, replacement, the next tracking system 10/26/10 analysis or design modification refueling - Post Outage prior to startup from the next outage Assessment refueling outage (1 R20), (1 R20) Report scheduled to be completed in the fourth quarter of 2010.
4/3012009 A description of the proposed Prior to the - Write-up from Completed mitigation activities will be start of 1R20 commitment on 9/28/10 provided as a supplemental tracking system response to GL 2004-02 prior to - FENOC letter the start of 1R20. dated 9/28/2010 6/16/2009 Should a steam generator tube Within 45 - Write-up from Ongoing Attachment
-2 inspection reveal an inwardly days of commitment deformed Alloy 800 sleeve, identification tracking system FENOC will report this to the of the -
NRC. The special report of the deformed Alloy 800 sleeve incident will sleeve include a root cause analysis, an assessment of the integrity of the sleeve/parent tube complex and identification of the associated corrective actions.
6/16/2009 The resolution of request for Within 30 - Write-up from Completed additional information items 2 and days of commitment on 7/14/09 3 requires a revision to the TS submittal of tracking system
! Letter L-08-307. The TS markups 132 letter dated July will be provided in a forthcoming 14,2009 letter. Details of the TS markups are included in Attachment 1.
6/30/2009 It is recognized that the NRC Within 90 - Write-up from Open review ofWCAP-16793-NP, days after commitment Revision 1, has not been issuance of tracking system completed. Any additional actions the final NRC required to address NRC safety questions will be addressed. evaluation on WCAP 16793-NP, Revision 1 6/30/2009 Emergency Operating Procedures By - Write-up from Completed for BVPS-1 will be revised to December commitment on enhance the steps that shut down 31,2009 tracking system 12/22/2009 two recirculation spray pumps prior to the transfer to recirculation. I I 613012009 Emergency Operating Procedures Prior to - Write-up from Completed for BVPS-2 will be revised to shut startup from commitment on down one of the recirculation the fall 2009 tracking system 11/20/09 spray system pumps supplying
- refueling - Post Outage the spray header when the
- outage Assessment containment pressure is reduced (2R14) Report below a predetermined value.
7/28/2009 FENOC also proposes to FENOC - Write-up from Revised on implement an amendment to intends to commitment 9/30/09 paragraph 8 of the existing implement tracking system Cancelled
[Parental] Guaranty to provide as this - Commitment on follows: The guarantor agrees to amendment Evaluation 12/18/09 submit revised financial by October Forms statements, financial test data, 1,2009 - Supplemental and a special auditor's report and letter dated
-3 reconciling schedule to the NRC November 24, annually within 90 days of the 2009 close of the parent guarantor's fiscal year. In addition, within the same 90 day period, FirstEnergy Nuclear Generation Corp.
(FENGENCo) will annually calculate the amount of decommissioning funding assurance required using the prepayment method as compared with the value of decommissioning trust fund assets available. The Guarantor will increase or decrease the Guaranty amount to cover the difference in value and provide Notice to NRC, in the guarantor's annual submission, if any change is made to the Guaranty amount as a result of the annual assessment. If the NRC disagrees with the amount of increase or decrease in the guaranty amount made in the annual assessment, upon Notice issued by NRC to FENGenCo, FEN GenCo shall promptly provide alternative additional assurance in a form and amount to be approved by the NRC.
1/29/2010 FENOC is continuing to support Within 180 - Write-up from Ongoing the industry Gas Accumulation days after commitment Management Team and T5 Task NRC tracking system Force (TSTF) activities regarding approval of the resolution of generic T5 . the Traveler.
changes via the T5TF Traveler process. FENOC will complete an evaluation and determine whether to adopt the Traveler at BVP5.
9/28/2010 Plant modifications will be Prior to - Write-up from Completed completed for BVP5-1 associated startup from commitment on with Cal-5il insulation removal the next tracking system 10/26/2010 that ensures that the requirements refueling - Work order of FENOC's revised methodology outage of assuming 100 percent (1R20, Fall destruction of Cal-5i1 to fines is 2010) met.
9/28/2010 Plant modifications will be Prior to - Write-up from Completed
, completed for BVP5-2 associated startup from commitment on
-4 with Cal-Sil insulation removal the next tracking system 4/4/2011 that ensures that the requirements refueling - Work order of FENOC's revised methodology outage of assuming 100 percent (1 R15, destruction of Cal-Sil to fines is Spring 2011) met.
19/28/2010 Plant modifications, repairing Prior to - Write-up from Completed andlor replacing NUKON startup from commitment on insulation will be completed on the the next tracking system 4/7/2011 3-inch and 6-inch BVPS-2 PORV refueling - Work order supply piping with appropriately outage applied stainless steel jacketing (1R15, i and sure-hold bands. Spring 2011) I 2/3/2011 FENOC will submit a new version
- April 1, 2011 - Write-up from Completed of the BVPS Cyber Security Plan commitment on to incorporate changes based on tracking system 4/6/2011 these response to the requests for - Commitment additional information Evaluation Form
- RAI Responses dated April 6, 2011
P. Harden -2 If you have questions or concerns, please contact Nadiyah Morgan at (301) 415-1016.
Sincerely, IRA!
Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
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