ML12348A353
| ML12348A353 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/28/2012 |
| From: | Peter Bamford Plant Licensing Branch 1 |
| To: | Pacilio M Exelon Nuclear |
| Bamford P NRR/DORL/LPL1-2 301-415-2833 | |
| References | |
| TAC ME9240 | |
| Download: ML12348A353 (11) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 December 28, 2012 ri 0'
Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - AUDIT OF EXELON GENERATION COMPANY, LLC'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME9240)
Dear Mr. Pacilio:
The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 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 regulatory commitments are being effectively implemented.
An audit of the commitment management program for Three Mile Island, Unit 1 (TMI-1), was performed during the last quarter of 2012, with the on-site portion of the audit taking place on December 10 and December 11, 2012. Based on the audit, the NRC staff concludes that: (1)
TMI-1 has implemented NRC commitments related to licensing activities on a timely basis; and, (2) overall, TMI-1 has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, fk~~
Peter Bamford, Project Manager Plant licensing Branch 1-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-289
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 EXELON GENERATION COMPANY, LLC TO THE NUCLEAR REGULATORY COMMISSION FOR THREE MILE ISLAND NUCLEAR STATION, UNIT 1 DOCKET NO. 50-289
1.0 INTRODUCTION AND BACKGROUND
The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 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), that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes" (ADAMS Accession No. ML003680088), contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 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. 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.
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 regulatory commitments are being effectively implemented. An audit of the Three Mile Island, Unit 1 (TMI
- 1) commitment management program was performed during the last quarter of 2012, with the on-site portion of the audit taking place at TMI-1 on December 10 and December 11, 2012. The audit reviewed commitments made since the previous audit conducted in August of 2009.
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,),
2.0 AUDIT PROCEDURE AND RESULTS The audit consisted of three major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed; (2) verification of the licensee's program for managing changes to NRC commitments; and (3) verification that all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews, 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,), Before the audit, the NRC staff searched ADAMS for licensee commitments associated with TMI-1 for verification, The review included licensing actions and licensing activities with NRC issuance dates between 2010 and 2012, License renewal commitments were excluded from the audit scope in accordance with the applicable NRC office instruction. The commitments included in the review are shown in Table 1, 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, 2.1.2 Audit Results Table 1 provides a summary of the audit for verification of the licensee's implementation of commitments, All commitments associated with licensing activities were verified to be completed, In addition, the NRC reviewed the licensee's corrective actions and extent of condition review related to previous commitment audit discrepancies, as documented in NRC letter dated October 1, 2009 (ADAMS Accession No, ML092590031), The NRC staff concludes that appropriate actions were taken by the licensee in response to the previously identified
- issues, 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 TMI-1 is contained in licensee procedure LS-AA-110, Revision 9, "Commitment Management" The audit reviews a sample of commitment changes, as shown in Table 2, that include changes that were or will be reported to the NRC, and changes that were not or will not be reported to
- 3 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.
2.2.1 Audit Results The NRC staff reviewed the licensee's procedure LS-AA-110, Revision 9, against NEI 99-04.
Section 6.1 of the procedure lists NEI 99-04 as a reference. The NRC staff found that LS-AA 110 generally follows the guidance of NEI 99-04 and provides detailed instructions for making regulatory commitments, tracking regulatory commitments, annotating documents to provide traceability of commitments, and for making changes to commitments. The NRC staff concludes that the procedure used by the licensee to manage commitments provides the necessary attributes for an effective commitment management program. Table 2 provides the specific details and results of the audit of commitment changes for TMI-1.
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, and it was determined that none had been misapplied.
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 reviewed. No misapplied commitments were identified in these documents.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that: (1) TMI-1 has implemented NRC commitments on a timely basis; and (2) TMI-1 has implemented an effective program for managing NRC commitment changes.
-4 4,0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT M, Newcomer 0, Atherholt R Miller M. Fitzwater K. Heisey R Ezzo B. McSorley D. Hull M. Harrison B, Shumaker Principal Contributor: P. Bamford Date: December 28,2012
Table 1 Written Commitments -
2010~2012 I
TMI~1 Submittal Date NRC TAC No.
NRC Issuance Summary of Commitment and Licensee Tracking Number (if applicable)
Licensee Implementation Status 09/29/2008 MD9762 Amendment No. 273, dated 05/27/2010, ADAMS Accession No. ML092740791 Control rod patch verification will be performed by moving each control rod to verify correct grouplrod assignment following any software recompile/download.
Complete; captured in procedure OP-TM-622 221, Section 1.3.
03/03/2009 ME0771 Exemption dated 06/28/2010, ADAMS Accession No. ML101310113 Install modification to prevent DH-V-6A/68 from spuriously opening in refueling outage 1R18.
Completed via work order C2019534 03/03/2009 ME0771 Exemption dated 06/28/2010, ADAMS Accession No. ML101310113 Install modification to add fixed 8-hour lighting to MU-V-189 in refueling outage 1 R 18.
Completed via work order C2021711 09/04/2009 ME1797 Letter dated 11/03/2009, ADAMS Accession No. ML093010455 Provide analysis to confirm enhanced once through steam generator can withstand large break loss-of-coolant-accident loads by 01/31/2010.
Notification of completion submitted to NRC by Exelon letter dated 01/29/2010, ADAMS Accession No. ML100290764.
09/04/2009 09/30/2010 ME1797 ME4795 NIA Relief Request, RR-10-02, dated 08/15/2011, ADAMS Accession No. ML112140397 Provide structural limit associated with the limiting location by 06/30/2012.
Provide NRC with results of ultrasonic examination of structural weld overlay on pressurizer spray nozzle.
Provided by letter dated 05/15/2012.
Provided by letter dated 12/02/2011.
05/14/2012 ME8639 NRC Letter dated 06/08/2012, ADAMS Accession No. ML12159A395 Communications Request #1 :
Provide an assessment of current communications systems and equipment used in an emergency... by 10/31/2012.
Responded by letter dated 10/31/2012.
05/14/2012 ME8639 NRC Letter dated 06/08/2012, ADAMS Accession No. ML12159A395 Communications Request #2:
Describe any interim actions that have been taken or are planned to be taken to enhance existing communications systems power supplies... by 06/11/12.
Responded by letter dated 06/11/2012.
Table 1 Written Commitments - 2010-2012 05/14/2012 ME8639 NRC Letter dated 06/08/2012, ADAMS Accession No. ML12159A395 Staffing Request #3: Identify how the augmented staff would be notified given degraded communications capabilities... by 06/11/2012.
Responded by letter dated 06/11/2012.
06/11/12 NIA NIA Commitment #2:
Programming of the 'Talk Around" radio frequency for Limerick Peach Bottom and TMI will be completed by December 7, 2012.
Completed for TMI-1.
During the reprogramming effort the licensee identified several missing or lost radios. All available radios were reprogrammed and steps taken to ensure that radios that had not been reprogrammed will not be used. An adequate number of properly programmed radios were verified to meet the requirements of the site emergency plan.
12-01 Table 2 Changed Commitments - 2010-2012 NRC Tracking Justification for change/deletion Source Change Notification Number Inspection and Commitment changed to historical (closed)
Yes Enforcement (lEB) 90 because the affected transmitters were all 01, Rosemount replaced.
transmitters 12-03 Yes Amendment #175 Technical Specification Commitment revised due to approval of a later standard.
12-06 TMlletter 5211-82-2301 Commitment changed to historical Yes because the action has been put into a procedure with reference to the original commitment.
12-08 Generic Letter (GL) 88 Commitment changed to historical based Yes 17 on reduced Inventory training, I incorporated in training plan.
12-09 Inspection and Commitment changed to historical Yes Enforcement Notice because Emergency Core Cooling System (lEN) 86-03 Pump Recirculation design was found to be acceptable and future changes are controlled by modification process.
12-10 GL 89-13 Commitment changed to historical Yes because original assessment action was completed and existing programs under the Quality Assurance Program provide for continuing controls.
12-12 Confirmatory Action Actions for unmitigated dissimilar butt Yes Letter NRR-07 -029 welds associated with pressurizer. All welds have been mitigated and commitment was closed.
12-13 GL 96-05 Commitment changed to reflect a subset Yes of values that are outliers to Joint Owners Group program which is contrary to original commitment. Justification reflects current design. Will be reported to NRC in next commitment change submittal.
12-02 1990 TMI-1 Integrated Eliminate commitment relating to ILRT No Leak Rate Test (ILRT) parameters. Current applicable
, Report C311-90-2049 parameters controlled by procedure.
TMI Letter C311-89-3288 Change to method for evaluation of Station No Blackout Diesel reliability determination to be consistent with current licensing basis (Updated Final Safety Analysis Report (UFSAR)).
12-04
Table 2 Changed Commitments - 2010*2012 Change Source Justification for change/deletion NRC Tracking Notification Number 12-05 TMI Letter C311-92-2003 Anticipated Transient Without Scram No Diversity description - Commitment deleted because information has been moved to UFSAR 12-07 Technical Specification Delete commitment regarding Review and No Change Request #86 Audit. Information is now contained in Quality Assurance Manual (Impacts TMI 2).
1122355-56 GL 90-03 Updates commitment to correct erroneous No document identification number.
- 11 ??n72-45 NRC Safety Evaluation Updates commitment to add reference No dated 8/28/81 documents.
1122355-53 TMI Letter C311-89-3246 Update commitment due to procedure No number change.
1122355-10 TMI Letter 5211-85-3262 Update commitment to add reference No documents.
1122355-57 TMI Letter C311-90-2073 Update commitment to add reference No documents.
1983T0123 GL 83-28 Commitment closed, superseded by Yes Institute of Nuclear Power Operations Training requirements.
. 5928-07 TMI Letter 5928-07 Commitment changed to implement more Yes 20263.001 20263 robust actions relative to B.5.b. actions.
1986T0063 TMI Letter 5211-86-2177 Commitment deleted. Calculation C-11 01 Yes 700-E420-015 justifies bus as not susceptible to multiple high impedence faults.
1987T0044 IEB 85-03 Commitment deleted. Valve design Yes aspects now covered by GL 89-10 Motor Operated valve (MOV) program. Testing covered by existing GL 96-05 commitments.
1989T0048 IEB 85-03 Commitment deleted. Valve design Yes aspects now covered by GL 89-10 MOV program. Testing covered by existing GL 96-05 commitments.
97056.02 GL 97-001 Deleted commitment to maintain a Reactor Yes Vessel Head Closure program because it is now covered by regulation (the revised 10 CFR 50.55a(g)(ii}(D>>.
1980T0096 I TMI Letter 5211-80-3078 Underground Pipe thrust block survey-Yes commitment deleted because condition I
has been corrected and has not recurred.
Table 2 Changed Commitments - 2010-2012 Change Source Justification for change/deletion NRC Tracking Notification Number 1987T0047 IEB 87-01 Commitment closed. Flow Accelerated Yes Corrosion program (subject of the IEB) is covered by another commitment.
5928-05 GL 2004-02 Deleted commitment because it was "one-Yes 20249.004 time" and has been completed.
5928-05 GL 2004-02 Deleted commitment because it was "one-Yes 20249~
time" and has been completed.
5928-0 2004-02 Deleted commitment because it was "one-Yes 20076."'"
time" and has been completed.
97093.19 TMI Letter 1920-98 Deleted commitment because it has been Yes 20145 superseded by TS Amendment 264 requirements for maintenance of control room habitability.
1989T0038 GL89-18 Deleted commitment because it was "one-Yes time" and has been completed.
1983T0132 TMI Letter 5211-87-3061 Deleted commitment - superseded by Yes current component Record List requirements in EP-011T.
5928-05 NRC Bulletin 2003-01 Deleted commitment, superseded by GL Yes 20269.001 2004-02 response. Guideline for alternate injection ER-TM-TSC-0018 is still maintained.
1983T0131 GL 83-28 Commitment has been deleted because it Yes was superseded by two other commitments (1985T0060 and 1985T0062).
1985T0034 GL 83-28 Commitment has been deleted because it Yes was superseded by two other commitments (1985T0060 and 1985T0062).
- 1985T0062 GL 83-28 Commitment has been deleted because its Yes requirements are covered by procedure CC-AA-204.
1985T0060 i GL 83-28 Commitment has been deleted because its Yes requirements are covered by procedure CC-AA-204.
1990T0050 TMI Letter C311-90-2073 Changes commitment on fire brigade Yes member training from 2 drills per year per person at TMI-1 to two drills per year per person at either TMI-1 or TMI-2. Fire brigade leader requirements are unchanged. Basis for change is that all drills are performed to the same standard regardless of location
December 28, 2012 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - AUDIT OF EXELON GENERATION COMPANY, LLC'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME9240)
Dear Mr. Pacilio:
The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 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 regulatory commitments are being effectively implemented.
An audit of the commitment management program for Three Mile Island, Unit 1 (TMI-1), was performed during the last quarter of 2012, with the on-site portion of the audit taking place on December 10 and December 11, 2012. Based on the audit, the NRC staff concludes that: (1)
TMI-1 has implemented NRC commitments related to licensing activities on a timely basis; and, (2) overall, TMI-1 has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, IRA!
Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289
Enclosure:
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
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