ML12228A516
| ML12228A516 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/22/2012 |
| From: | Wang A Plant Licensing Branch IV |
| To: | Entergy Operations |
| Wang A | |
| References | |
| TAC ME6787 | |
| Download: ML12228A516 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 22, 2012 Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME6787)
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 Grand Gulf Nuclear Station, Unit 1 (GGNS) commitment management program was performed at the plant site during the period August 4-5,2011. 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 GGNS. 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.
Sincerely,
~vJOJv~
Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416
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 (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION (NRC)
GRAND GULF NUCLEAR STATION. UNIT 1 DOCKET NO. 50-416
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 Grand Gulf Nuclear Station, Unit 1 (GGNS), commitment management program was performed at the plant during the period August 4-5, 2011, and discussed on August 5, 2011, with members of the Entergy Operations, Inc. (Entergy, the licensee), staff. The audit staff reviewed commitments made by Entergy since the previous audit on February 2008, which was documented in an audit report dated March 20,2008 (ADAMS Accession No. ML080700209). The audit consisted of two major parts: (1) verification of the licensee's Enclosure
- 2 implementation of NRC 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 a
(bulletins, generic letters, etc.). Before the audit, the NRC staff performed 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 stJtr*s audit in each of the samples selected. The documents included summary sheets providing ~he status of the commitment and the appropriate backup documentation. as needed (i.e .. plant procedures.
incoming/outgoing records, and/or other plant documentation).
- 3 2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes 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 that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
GGNS commitments are tracked in accordance with the licensee's Nuclear Management Manual Procedure EN-U-110, Revision 4, "Commitment Management Proglram." The licensee enters commitments made to the NRC using a commitment tracking datab~se 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 ¢ommitments 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 36,000 licensee defined commitments. At the time of the audit, the licensee was tracking approximately 5,300 items in the LRS as regulatory commitments of which 77 were deSignated as "OPEN" actions items. There also approximately 900 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-U-11 0, including the status of their completion.
After review of the commitments selected for the audit, the NRC staff concl4ded that the licensee's commitment tracking program had captured aU of the regulatory ¢ommitments 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 th~ change maintains satisfactory implementation of the commitment. Attachment 9.3 of procedure EN-U-110, "Commitment Change Evaluation Process," is flowchart describing the change process.
Procedure EN-U-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-U-110, Attachment 9.4, for handling commitment changes is consistent with the guidance in NEI99-04.
2.2.2 Procedure Implementation Assessment The NRC staff reviewed documentation generated by the licensee categori~ed 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.
-4 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.
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 origlinates 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 concluded that the licensee's commitments were traceable and personnel were knowledgeable in utilizing the commitment tracking system.
2.3 Audit Observations and Suggestions I
As stated above, the licensee's procedure EN-Ll-110 was found to be consjstent 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 generate$ a Licensing Status Report (LSR) at the beginning of each week for assigned licensing personnel and the personnel
-5 look-ahead of upcoming actions in the LRS. Approximately every 2 to 3 weeks, a gO-day look-ahead report is generated to help ensure that regulatory commitments are not missed. In addition, special look-ahead reports are also generated, for example, for the extended power uprate (EPU) personnel to assure they are aware of the numerous regulatory commitments related to the EPU.
The NRC staff asked if periodic assessments are performed to evaluate for the compliance with the requirements of EN-Ll-110. Entergy stated that it has not performed such "snapshot" assessments and noted that there is no such requirement to do so. Entergy stated it does conduct a periodic audit of the LRS electronic log for incoming and outgoing correspondence to ensure that incoming letters from the NRC and outgoing letters to the NRC have been reviewed and commitments added to the LRS database. Entergy noted that EN-Ll-110, Revision 5, has added a new requirement to conduct a snapshot self-assessment of the regulatory commitment tracking process. The procedure has this snapshot self-assessment being performed prior to the NRC conducting the regulatory audit based on the list of commitments requested by the NRR Project Manager. The NRC staff believes that the above processes are important for maintenance of the regulatory commitment tracking process. The NRC staff does recommend that since the audits are only performed tri-annually that a more frequent self-assessment be performed, perhaps yearly. While NRC audits tend to look at compliance with regulatory commitments, the licensee's self-assessments might provide a more comprehensive assessment of the licensee's 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 CONTAgTED FOR THIS AUDIT Rita Jackson Christina Perino Jeffery Seiter
Attachment:
Table 1, Audited: Written Commitments and Related Information Principal Contributors: A. Wang Date: August 22, 2012
TABLE 1 AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION Grand Gulf U.S. Nuclear Summary of Commitment and Nuclear Station Regulatory Entergy Operations, Inco's Licensee Implementation Item (GGNS) Commission GGNS Source (Entergy's, the Licensee's) Status (Documents listed No. Submittal (NRC) TAC No. Document NRC Issuance Tracking Number are in GGNS Database) 1 6/8/2011 ME6436 GNRI-2011/00060 NRC Bulletin 2011-01: The bulletin required a 30- and 60 Completed via responses to 7/11/2011 Mitigating Strategies day response. the NRC dated 6/812011 dated 5/11/2011. (GNRO-2011/00041) and 7/11/2011 (GNRO-2011-00051).
2 2/15/2011 ME2644 GNRO-2011/00002 Request for additional Entergy made a commitment to Closed via letter dated information (RAI) dated change Sections 4.3 and 4.4.3 of 4/4/2011 to the NRC.
1217/2010. the GGNS Cyber Security Plan in accordance with the RAI responses as described in Attachment 1 of the letter dated 2/15/2011.
3 212512010 MD7831 GNRO-20 10/00016 RAI dated 1/6/2010. Per Generic letter (GL) 2008-01, Closed by 6/10/2012, via Attachment Entergy made a commitment to Corrective Action CR-GGN revise the procedures to establish 2009-06249.
and implement a shorter period of vent time before a condition report is prepared by 6/30/2010.
4 8/27/2009 ME2474 GNRI-2010/00051 License Amendment Staff approval of license LBDCR 09037 implemented No. 184 dated amendment request (LAR) to the LAR by 5/19/2010 and 3/25/2010. change the minimum critical power the Cycle 18 started on ratio safety limit to be implemented 5/27/2010.
before operation of Cycle 18.
5 2/20/2009 MD4675 GNRO-2009/00016 Issuance of safety Entergy made the following TSTF was issued on evaluation (SE) and regulatory commitment that within 5/11/2010. Closed via LAR basis for denial of 6 months of the approval of the dated 11/8/2010 (GNRO proposed technical Technical Specification Task Force 2010/00067) to adopt generic specification (TS) (TSTF): Enteigy wnl follow the TSTF-4~footrrotes;-'
change related to efforts of the TSTF-493 effort to Condensate Storage resolve the instrument setpoint Tank (CST) Level-low issue discussed in Regulatory Issue setpoint. Summary (RIS)-2006-17. If the CST level-low setpoint is affected by the approved TSTF traveler, Entergy will submit a separate LAR
- c. - L.. - - -.... -- -
c!e> approve the _ge_ne--,"ic~hange.
Attachment
-2 Grand Gulf u.s. Nuclear Summary of Commitment and Nuclear Station Regulatory Entergy Operations, Inc:s Licensee Implementation Item (GGNS) Commission GGNS Source (Entergy's, the Licensee's) Status (Documents listed No. Submittal (NRC) T AC No. Document NRC Issuance Tracking Number are in GGNS Database) 6 6/30/2008 MD5913 GNRO-2008/00014 Issuance of Amendment Entergy will implement TS and verify LBDCR 08002 verified No. 180 via letter dated applicability of TSTF-475. applicability of TSTF and 12/31/2008. implemented the TS by 119/2009.
7 3/17/1997 CNRO-97/00004 GL 96-05, Periodic This is a commitment change Commitment Change Verification of Design- evaluation to revise the GL 96-05 Evaluation (CCE) Form CCE Basis Capability of commitment (one time extension for 2011-0001 provided the safety-related motor valve 1E51 F078. justification for this change to operated valves. a commitment.
8 6/3/2003 MD4536 CNRO-03/00025 NRC Order EA-03-038 This commitment was relaxed per CCE Form CCE-2010-0003 NRC letter dated 6/8/2009 and the provided the justification for commitment can be closed. this change to a commitment.
9 7/13/2006 MD1749 CNRO-06/00034 Request acceptance Entergy will notify the manufacturer Ongoing and being letter dated 7/18/2006. (as well as the U.S. nuclear implemented via Procedure industry) of any defects experienced EN-RP-503.
during the use of the Mururoa V4F1R devices.
10 9/8/2010 ME4679 GNRO-2010/00056 Issuance of Amendment Entergy committed to change Pa to This was implemented for the No. 191 via letter dated the maximum calculated value per containment by Procedure 7/18/2012. Appendix J. 06-ME-1 M1 0-0-0002 dated 8/6/2012 and for local leak rate test by procedure 17-S-05-1 dated 8/9/2012.
11 5/18/2010 ME2531 GNRO-2010/00035 Issuance of Amendment Entergy will conduct the oscillation This OPRM monitoring is still No. 188 via letter dated power range monitor (OPRM) ongoing as the outage ended 3/28/2012. monitoring period for 90 days on 5/24/2012.
following startup.
-2 If you have any questions, please contact me at 301-415-1445.
Sincerely, IRA!
Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION PUBLIC LPLIV r/f RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMGrandGulf Resource RidsOgcRp Resource RidsRgn4MailCenter ADAMS Accession No: ML12228A516 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NRR/LPL4/PM NAME AWang JBurkhardt MMarkley AWang DATE 8/17/12 8/16/12 8/22/12 8/22/12 OFFICIAL RECORD COpy