ML12342A016

Audit of the Licensee'S Management of Regulatory Commitments

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

AUDIT

SUMMARY

LIST OF COMMITMENTS INCLUDED IN THE AUDIT No. Category Action Letter No. Letter Date Commitment Completion Notes Request &

No. Completion Date 1 Regulatory 294764 RNP-RA/08-0099 10/14/2008 Implement a program for Procedure Correspondence on detection of gas intrusion in the PLP-085, Emergency Generic Letter 4/28/2009 safety injection, residual heat Core Cooling System (GL) 2008-01 removal, and containment spray Gas Management systems. Program was updated in the agreed timeframe according to the GL 2008-01 correspondence.

2 Regulatory 294764 RNP-RA/08-0099 10/14/2008 Install additional vents as The licensee completed Correspondence on determined necessary for system the commitment during GL 2008-01 11/4/2008 venting and perform ultrasonic refueling outage (RO) 25 testing for voids at the locations through Work Order where voids were found prior to 1381995 and and during RO25. Engineering Change 70679.

3 Regulatory 298322 RNP-RA/08-0099 10/14/2008 Review and revise fill and vent, The licensee revised Correspondence on and maintenance procedures to procedures OP-201 GL 2008-01 10/16/2008 ensure adequate control of gas Residual heat Removal accumulation prior to System and OP-202 startup from RO25. Safety Injection and Containment Spray System during RO 25.

4 Regulatory 422538 RNP-RA/10-0007 3/30/2010 A commitment is being made The licensee completed Correspondence on pertaining to performance of the strainer testing and GL 2004-02 10/08/2010 additional strainer testing. provided the results to the NRC in a letter dated 10/08/2010.

Attachment

No. Category Action Letter No. Letter Date Commitment Completion Notes Request &

No. Completion Date 5 Regulatory 333711 RNP-RA/08-0124 12/17/2008 A commitment is being made, in The commitment is Correspondence on response to Request Number 25, being tracked in GL 2004-02 Pending pertaining to verification that plant PassPort and has been Completion conditions are bounded by the given an appropriate final WCAP-16793-NP and the due date consistent with final NRC safety evaluation when the intent/scope of it is issued. GL-2004-02.

The NRC staff has not issued the safety evaluation related to WCAP-16793.

6 Commitment 00289359 PE&RAS-08-037 10/6/2008 Removal of the plant-specific The commitment was associated with technical specification (TS) completed before the licensing amendment 8/10/2009 requirements will be performed agreed upon timeframe.

request (LAR) to concurrently with the Eliminate Work Hour implementation of the 10 CFR Controls to Comply Part 26, Subpart I requirements.

with the Revised 10 CFR Part 26 7 Commitment 269157 RNP-RA/09-0054 6/19/2009 Complete a plant modification in The LAR was originally Associated with LAR accordance with the engineering submitted on 11/29/2007 for TS Change 3.3.1 7/18/2010 change process, which will be and was withdrawn on Reactor Protection implemented to conduct the 6/24/2008. The licensee System required plant changes. resubmitted the LAR on Instrumentation 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 Letter No. Letter Date Commitment Completion Notes Request &

No. Completion Date 8 Commitment 390931 RNP-RA/09-0103 12/16/2009

• Monitoring for tube slippage as The commitments were associated with TS part of the SG tube inspection completed during RO 26 change regarding 6/17/2010 program will be conducted. and in the agreed upon Steam Generator

• A one-time verification of the timeframe.

(SG) Alternate expansion locations will be Repair Criteria LAR 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.

No. Category Action Letter No. Letter Date Commitment Completion Notes Request &

No. Completion Date 9 Commitment 396357 RNP-RA/10-0019 3/11/2010 For the condition monitoring The commitment was associated with assessment, the component of completed RO 26 and in supplemental 6/17/2010 operational leakage from the prior the agreed upon information for TS cycle from below the H* distance timeframe.

change regarding SG will be multiplied by a factor of Alternate Repair 1.82 and added to the total Criteria LAR 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.

10 Commitment 438394 RNP-RA/11-0013 3/24/2011 Revise and implement Procedure associated to reply to 438396 OPS-NGGC-1313, "Standards for OPS-NGGC-1313 was a Notice of Violation 455261 3/30/2011 Operations Shift/Training Crew revised before the EA-10-257 Performance Improvement," to agreed upon timeframe.

require that Simulator Crew Evaluation Summaries and The licensee had Individual Evaluation Competency several Action Request Grading forms are reviewed Nos. for this commitment during the Shift Management and its completion was Review Meetings. difficult to track in PassPort.

No. Category Action Letter No. Letter Date Commitment Completion Notes Request &

No. Completion Date 11 Commitment 455261 RNP-RA/11-0013 3/24/2011 Initiate organizational The commitment was associated to reply to effectiveness review committees completed before the a Notice of Violation 5/9/2011 in accordance with ADM-NGGC- agreed upon timeframe.

EA-10-257 0113, Performance Planning and Monitoring. The commitment completion timeframe was difficult to track in PassPort.

12 Commitment 438396 RNP-RA/11-0013 3/24/2011 Complete Management and The commitment was associated to reply to 455261 Supervisory Leadership completed on the agreed a Notice of Violation 5/12/2011 Assessments through panel timeframe.

EA-10-257 process for Management and Supervisory individuals new to The licensee had positions since August 2010. several Action Request Nos. for this commitment and its completion was difficult to track in PassPort.

No. Category Action Letter No. Letter Date Commitment Completion Notes Request &

No. Completion Date 13 Commitment 455261 RNP-RA/ 3/24/2011 Add the following requirements to The commitment was associated to reply to 438394 11-0013 OMM-001-5, Training and completed before the a Notice of Violation 5/4/2011 Qualification: agreed upon timeframe.

EA-10-257

• The Manager - Shift Operations (MSO) shall review the Institute of The licensee had several Nuclear Power Operations (INPO) Action Request Nos. for Performance Objectives and this commitment and its Criteria for OP.1 and participate completion was difficult to with INPO on a Crew Performance track in PassPort.

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.

14 Commitment 490738 RNP-RA/11-0038 9/28/2011 Capsule U will be withdrawn at 38.0 The NRC approved the associated to the effective full power years or during reactor vessel surveillance revision to the 1/25/2012 the scheduled outage after the 80 capsule removal schedule Reactor Vessel year peak vessel fluence is on 12/21/2011. The Surveillance Capsule reached. licensee updated the Final removal Schedule Safety Analysis Report in Revision 24 to include the commitment.

15 Commitment 499929 RNP-RA/ 2/10/2012 Carolina Power & Light will adopt The commitment is being associated TS 11-0095 Pending the TS Bases changes as shown in tracked in PassPort and regarding Missed Attachment V upon implementation has been given an Surveillances using of this license amendment. appropriate due date the Consolidated Line consistent with the Item Improvement intent/scope of the LAR.

Process

'.. 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