ML12342A016
| ML12342A016 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/12/2012 |
| From: | Billoch-Colon A Plant Licensing Branch II |
| To: | William Gideon Carolina Power & Light Co |
| Billoch, Araceli | |
| References | |
| TAC ME8190 | |
| Download: ML12342A016 (13) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 12, 2012 Mr. William R. Gideon Vice President H. B. Robinson Steam Electric Plant Carolina Power & Light Company 3581 West Entrance Road Hartsville, SC 29550 SUB~IECT: H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME8190)
Dear Mr. Gideon:
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 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 if regulatory commitments are being effectively implemented.
An audit of H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP) commitment management program was performed at the plant site in Hartsville, South Carolina, between September 10, and September 12,2012. The NRC staff concludes, based on the audit, that HBRSEP (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.
W.Gideon
-2 Please direct any inquiries to me at 301-415-3302 or via e-mail atAraceli.Billoch@nrc.gov.
Sincerely, Araceli T. Billoch Col6n, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
Audit Report cc w/encl: Distribution via ListServ
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 DOCKET NO. 50-261
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 if 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 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 H.B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP) commitment management program was performed at the plant site in Hartsville, South Carolina, between September 10, and September 12,2012. The audit reviewed commitments made since the previous audit completed between June 11 and June 12, 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.
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.
Enclosure
-2 2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. It 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 the Licensee Event Reports or in response to the 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 its 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.,
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, 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 the relevant plant procedure to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC. The procedure reviewed was REG-NGGC-0110, "Regulatory Commitment." In addition, the NRC staff reviewed a sample of open and closed commitments to confirm that the licensee had 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 procedure REG-NGGC-011 0 to the guidance in NEI99-04. As a result of this comparison, the NRC staff found that the procedure implemented by the licensee is consistent with the NEI guidance for identifying, managing, and closing commitments. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in REG-NGGC-011 O.
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.
3 For this part of the audit, the NRC staff reviewed 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 the commitments reviewed had been closed in a manner that fully satisfied the commitments made to the NRC.
Based on the sample of commitments reviewed, the NRC staff found that commitments tracked in accordance with procedure REG-NGGC-0110 were implemented satisfactorily. Also, based on the sample of licensee submittals and the NRC safety evaluations reviewed, the NRC staff found that commitments were tracked as specified by procedure REG-NGGC-0110. However, the NRC staff identified several instances where the tracking of the commitments in PassPort was difficult during the audit. These instances, as well as the summary of the overall results of the NRC staff review of the audit, are noted in the attached audit summary table.
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 HBRSEP is contained in the procedure REG-NGGC-011 O.
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 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.
2.3 Review to Identify Misapplied Commitments The commitments reviewed for this audit were also evaluated to determine if they had been misapplied. A commitment is considered to be misapplied if the action comprising the commitment was relied on by the NRC staff in making a regulatory decision, such as a finding of public health and safety in an NRC safety evaluation associated with a licensing action.
Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (i.e., commitments used to ensure safety).
Each of the commitments selected for the audit sample were reviewed to determine if any had been misapplied. No misapplied commitments were identified for HBRSEP.
-4 2.3.1 Review of Safety Evaluation Reports for Licensing Actions since the Last Audit to Determine if They Are Properly Captured as Commitments or Obligations In addition to the commitments selected for the audit sample, all license amendment safety evaluations, exemptions and relief request safety evaluations that have been issued for a facility since the last audit were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above.
The NRC staff reviewed the safety evaluation reports for the completed licensing actions since the last audit and no misapplied commitments were identified for HBRSEP.
2.4 Audit Results The attached Audit Summary also provides details of this portion of the audit and its results.
The NRC staff found that procedure REG-NGGC-011 0 was consistent with the guidance found acceptable in NEI 99-04. The NRC staff concludes that the procedure used by the licensee to manage commitment changes is appropriate and that the licensee followed the process.
The NRC staff reviewed the documentation associated with the changed commitments. The NRC staff observed that, HBRSEP had complete records and documented changes, appropriately. However, in some instances, as noted in the attached audit summary table, the traceability of the completion dates of the commitments were difficult to track in PassPort.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, (1) HBRESP has implemented NRC commitments on a timely basis, and (2) HBRSEP has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Licensing and Regulatory Programs: Richard Hightower Scott Connelly Principal Contributor: Araceli T. Billoch Colon
Attachment:
Summary of Audit Results
Attachment AUDIT
SUMMARY
LIST OF COMMITMENTS INCLUDED IN THE AUDIT No.
Category Action Request No.
Letter No.
Letter Date Completion Date Commitment Completion Notes 1
Regulatory Correspondence on Generic Letter (GL) 2008-01 294764 RNP-RA/08-0099 10/14/2008 4/28/2009 Implement a program for detection of gas intrusion in the safety injection, residual heat removal, and containment spray systems.
Procedure PLP-085, Emergency Core Cooling System Gas Management Program was updated in the agreed timeframe according to the GL 2008-01 correspondence.
2 Regulatory Correspondence on GL 2008-01 294764 RNP-RA/08-0099 10/14/2008 11/4/2008 Install additional vents as determined necessary for system venting and perform ultrasonic testing for voids at the locations where voids were found prior to and during RO25.
The licensee completed the commitment during refueling outage (RO) 25 through Work Order 1381995 and Engineering Change 70679.
3 Regulatory Correspondence on GL 2008-01 298322 RNP-RA/08-0099 10/14/2008 10/16/2008 Review and revise fill and vent, and maintenance procedures to ensure adequate control of gas accumulation prior to startup from RO25.
The licensee revised procedures OP-201 Residual heat Removal System and OP-202 Safety Injection and Containment Spray System during RO 25.
4 Regulatory Correspondence on GL 2004-02 422538 RNP-RA/10-0007 3/30/2010 10/08/2010 A commitment is being made pertaining to performance of additional strainer testing.
The licensee completed the strainer testing and provided the results to the NRC in a letter dated 10/08/2010.
No.
Category Action Request No.
Letter No.
Letter Date Completion Date Commitment Completion Notes 5
Regulatory Correspondence on GL 2004-02 333711 RNP-RA/08-0124 12/17/2008 Pending Completion A commitment is being made, in response to Request Number 25, pertaining to verification that plant conditions are bounded by the final WCAP-16793-NP and the final NRC safety evaluation when it is issued.
The commitment is being tracked in PassPort and has been given an appropriate due date consistent with the intent/scope of GL-2004-02.
The NRC staff has not issued the safety evaluation related to WCAP-16793.
6 Commitment associated with licensing amendment request (LAR) to Eliminate Work Hour Controls to Comply with the Revised 10 CFR Part 26 00289359 PE&RAS-08-037 10/6/2008 8/10/2009 Removal of the plant-specific technical specification (TS) requirements will be performed concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements.
The commitment was completed before the agreed upon timeframe.
7 Commitment Associated with LAR for TS Change 3.3.1 Reactor Protection System Instrumentation 269157 RNP-RA/09-0054 6/19/2009 7/18/2010 Complete a plant modification in accordance with the engineering change process, which will be implemented to conduct the required plant changes.
The LAR was originally submitted on 11/29/2007 and was withdrawn on 6/24/2008. The licensee resubmitted the LAR on 6/19/2009 and the NRC approved the LAR on 3/27/2010.
The licensee completed the commitment according to the issued LAR. However, in PassPort the licensee did not properly capture the background of the LAR as resumed above.
No.
Category Action Request No.
Letter No.
Letter Date Completion Date Commitment Completion Notes 8
Commitment associated with TS change regarding Steam Generator (SG) Alternate Repair Criteria LAR 390931 RNP-RA/09-0103 12/16/2009 6/17/2010
- Monitoring for tube slippage as part of the SG tube inspection program will be conducted.
- A one-time verification of the expansion locations will be conducted to determine if any significant deviations exist from the top of the tubesheet to the bottom of the expansion transition. If any significant deviations are found, the condition will be entered into the plant corrective action program and be dispositioned.
Areas of inservice SG tubes within the tubesheet that are not fully expanded will be included in the scheduled inspection and the 17.28 inch tubesheet inspection limitation will not be applied to the areas of these tubes that are not fully expanded.
The commitments were completed during RO 26 and in the agreed upon timeframe.
No.
Category Action Request No.
Letter No.
Letter Date Completion Date Commitment Completion Notes 9
Commitment associated with supplemental information for TS change regarding SG Alternate Repair Criteria LAR 396357 RNP-RA/10-0019 3/11/2010 6/17/2010 For the condition monitoring assessment, the component of operational leakage from the prior cycle from below the H* distance will be multiplied by a factor of 1.82 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 1.82 and compared to the observed operational leakage. If necessary, an administrative operational leakage limit will be established to not exceed the calculated value.
The commitment was completed RO 26 and in the agreed upon timeframe.
10 Commitment associated to reply to a Notice of Violation EA-10-257 438394 438396 455261 RNP-RA/11-0013 3/24/2011 3/30/2011 Revise and implement OPS-NGGC-1313, "Standards for Operations Shift/Training Crew Performance Improvement," to require that Simulator Crew Evaluation Summaries and Individual Evaluation Competency Grading forms are reviewed during the Shift Management Review Meetings.
Procedure OPS-NGGC-1313 was revised before the agreed upon timeframe.
The licensee had several Action Request Nos. for this commitment and its completion was difficult to track in PassPort.
No.
Category Action Request No.
Letter No.
Letter Date Completion Date Commitment Completion Notes 11 Commitment associated to reply to a Notice of Violation EA-10-257 455261 RNP-RA/11-0013 3/24/2011 5/9/2011 Initiate organizational effectiveness review committees in accordance with ADM-NGGC-0113, Performance Planning and Monitoring.
The commitment was completed before the agreed upon timeframe.
The commitment completion timeframe was difficult to track in PassPort.
12 Commitment associated to reply to a Notice of Violation EA-10-257 438396 455261 RNP-RA/11-0013 3/24/2011 5/12/2011 Complete Management and Supervisory Leadership Assessments through panel process for Management and Supervisory individuals new to positions since August 2010.
The commitment was completed on the agreed timeframe.
The licensee had several Action Request Nos. for this commitment and its completion was difficult to track in PassPort.
No.
Category Action Request No.
Letter No.
Letter Date Completion Date Commitment Completion Notes 13 Commitment associated to reply to a Notice of Violation EA-10-257 455261 438394 RNP-RA/
11-0013 3/24/2011 5/4/2011 Add the following requirements to OMM-001-5, Training and Qualification:
Performance Objectives and Criteria for OP.1 and participate with INPO on a Crew Performance Observation (preferred) or participate in an as found simulator evaluation at an off Progress Energy system nuclear plant that is recognized as a leader by INPO in the conduct of operations, either prior to or within 6 months of being promoted to MSO.
- On an annual basis, conduct a paired observation with the Operations Functional Area Manager.
The commitment was completed before the agreed upon timeframe.
The licensee had several Action Request Nos. for this commitment and its completion was difficult to track in PassPort.
14 Commitment associated to the revision to the Reactor Vessel Surveillance Capsule removal Schedule 490738 RNP-RA/11-0038 9/28/2011 1/25/2012 Capsule U will be withdrawn at 38.0 effective full power years or during the scheduled outage after the 80 year peak vessel fluence is reached.
The NRC approved the reactor vessel surveillance capsule removal schedule on 12/21/2011. The licensee updated the Final Safety Analysis Report in Revision 24 to include the commitment.
15 Commitment associated TS regarding Missed Surveillances using the Consolidated Line Item Improvement Process 499929 RNP-RA/
11-0095 2/10/2012 Pending Carolina Power & Light will adopt the TS Bases changes as shown in Attachment V upon implementation of this license amendment.
The commitment is being tracked in PassPort and has been given an appropriate due date consistent with the intent/scope of the LAR.
'.. ML12342A016 OFFICE LPL2-2/PM LPL2-2/LA(lT}
LPL2-2/LA LPL2-2/BC LPL2-2/PM NAME ABiliochCot6n FKeith BClayton JQuichocho(A)
ABiliochCol6n DATE 12/6/12 12/11/12 12/12/12 12/12/12 12/12/12