ML12356A495
| ML12356A495 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/31/2012 |
| From: | Orf T Plant Licensing Branch II |
| To: | Nazar M Florida Power & Light Co |
| Orf, T J | |
| References | |
| TAC ME8077, TAC ME8078 | |
| Download: ML12356A495 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 December 31,2012 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420
SUBJECT:
ST. LUCIE, UNITS 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME8077 AND ME8078)
Dear Mr. Nazar:
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 the regulatory commitments are being effectively implemented.
An audit of the S1. Lucie Plant commitment management program was performed at the plant site during the period November 14 through 16, 2012. The NRC staff concludes that, based on the above audit, (1) the licensee has implemented or is tracking for future implementation regulatory commitments; (2) the licensee has implemented a program to manage regulatory commitment changes; and (3) the regulatory commitments are properly characterized as commitments versus obligations.
M. Nazar -2 Should you have any questions regarding this letter, please contact me by phone at (301) 415-2788 or via email at Tracy.Orf@nrc.gov.
Sincerely, Tracy J. Orf, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-335 and 50-389
Enclosure:
Audit Report cc w/encl: Distribution via Listserv
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS ST. LUCIE PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389
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, 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, report 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 the regulatory commitments are being effectively implemented. An audit of the S1. Lucie Plant commitment management program was performed at the plant site during the period November 14 through 16. 2012. The audit reviewed commitments made since the previous audit on February 4, 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. 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.
2.1.1 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 during the last 3 years 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 (TSs), 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 found that the licensee's commitment tracking programs had captured aU the regulatory commitments that were identified by the NRC staff before and during the audit. The NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit.
-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 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 St. Lucie Plant is contained in Administrative Procedure ADM-25.05, Revision 4. 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.
2.2.1 Audit Results The attached Audit Summary also provides details of this portion of the audit and its results.
ADM-25.05, Revision 4, contains detailed instructions regarding changes to commitments, including the need to inform the NRC. If the changes were evaluated as needing prior NRC notification, they were included in an annual summary report. The NRC staff found that the licensee's commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before and during the audit. The NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit.
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 NRC staff relied on the action comprising the commitment 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 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.
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 commitments selected for the audit sample, all license amendment safety evaluations, exemptions, and relief request safety evaluations that have been issued for a facility during the last 3 years were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above.
- 4
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit, (1) the licensee has implemented or is tracking for future implementation regulatory commitments; (2) the licensee has implemented a program to manage regulatory commitment changes; and (3) the regulatory commitments are properly characterized as commitments versus obligations.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Ken Frehafer Richard Sciscente Principal Contributor: Tracy J. Ort Date: December 31,2012
Attachment:
Summary of Audit Results
AUDIT
SUMMARY
IMPLEMENTATION OF COMMITMENTS:
- 1. Update the Inservice Testing Program to reflect changes to plant pumps and valves under extended power uprate (EPU) conditions.
Documents reviewed: ADM-29.01A, Revision 9 PSL-ENG-SEMS-11-003, Revision2 Deficiencies found: None
- 2. Provide operator training to account for increased EPU power level and resultant plant changes.
Documents reviewed: PSL OPS 0702406 PSL OPS 0702409A PSL OPS 0702521A PSL OPS 07025218 PSL OPS 0702521C PSL OPS 0702521E PSL OPS 072521 D PSL OPS 0802522 PSL OPS 0813021 Deficiencies found: None
- 3. Implement modifications to provide radiation shielding for reactor auxiliary building heating, ventilation, and air conditioning components identified in the EPU licensing report (LR)
Section 2.3.1, "Environmental Qualification of Electrical Equipment."
Documents reviewed: EC246568 screen capture WO 40042768 screen capture WO 40042768-05 screen capture EC246568, EC Form-110, DCP text, Revision 6 Turnover package Deficiencies found: None
- 4. Implement modifications to increase safety injection tank (SIT) design pressure for EPU conditions described in LR Section 2.8.5.6.3, "Emergency Core Cooling System and Loss-of-Coolant Accidents."
Documents reviewed: EC 246564, Revision 7 SIT Requalification PCM-10053 Form, Rev 7.2 Turnover package Attachment
- 2 Deficiencies found: None
- 5. Implement modifications necessary to accommodate the simultaneous hot and cold leg injection requirements for EPU conditions as described in LR Section 2.8.5.6.3, "Emergency Core Cooling System and Loss-of-Coolant Accidents."
Documents reviewed: EC246559, PCM-10047, Revision 6 ADM-29.01A, Revision 9 Turnover package Deficiencies found: None
- 6. Implement modifications to install a leading edge flow meter (LEFM) as described in LR Section 2.4.4, Measurement Uncertainty Recapture Power Uprate, and update Updated Final Safety Analysis Report (UFSAR) Section 13.8, "Licensee-Controlled Technical Specification Requirements," to include Limiting Conditions for Operation and Action Statements for the LEFM system.
Documents reviewed: EC246552, Revision 5 LEFM 2012-07-10, Unit 1 System Review Letter Turnover package Deficiencies found: None
- 7. Implement modifications to the ac electrical busses as described in LR Section 2.3.3, "AC
[alternating current] Onsite Power System."
Documents reviewed: PCM 10036 (EC246548), Revision 4 EC246548, Partial SATS, A Train WO 4006682901 Turnover package Deficiencies found: None
- 8. Revise the administrative controls for the main containment purge isolation valves such that they are maintained closed in MODES 1, 2, 3 and 4.
Document reviewed: 1-0530021-070 Deficiencies found: None
- 9. Implement modifications to pipe supports for systems impacted by loads due to EPU conditions, as described in LR Section 2.2.2.2, "Balance of Plant Piping, Components, and Supports."
- 3 Documents reviewed: EC246565, Revision 3 WO 4006395201 Turnover package Deficiencies found: None
- 10. Revise applicable procedures to accommodate operator actions during station blackout at EPU conditions, as described in LR Section 2.11, "Human Factors."
Document reviewed: 1-EOP-10, Revision 20, "Station Blackout" Deficiencies found: None
- 11. Implement a Metamic' insert surveillance program as described in LR Section 2.8.6.2, "Spent Fuel Storage," and update the UFSAR to include the program requirements.
Document reviewed: 0-OSP-67.01, Revision 2 Deficiencies found: None
- 12. The following information will be maintained in site procedures:
a) The conditions necessary to sequester site personnel that are consistent with the conditions specified in the St. Lucie exemption request.
b) Provisions for ensuring that personnel who are not performing duties are provided an opportunity as well as accommodations for restorative rest.
c) The condition for departure from the exemption is based on the Emergency Coordinator's determination that adequate staffing is available to meet the requirements of Title 10 of the Code of Federal Regulations, Sections 26.205(c) and (d).
Document reviewed: 0005753, Revision 67 Deficiencies found: None
-4 MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS:
ADM-2S.0S, Revision 4, "!\IRC Commitment Management Program" is the licensee's procedure for controlling commitments. This procedure provides controls for establishing, modifying, deleting, and tracking commitments to closure and adopts the NEI 99-04 guidance related to control of commitments. Guidance is provided regarding evaluation of proposed changes to commitments in terms of safety and regulatory significance, timely notification to the NRC of changes, and management and changes of commitments.
Two changes to commitments were made during the review interval. One related to communications during emergency operations, and another related to the periodic review of motor-operated valves. In both pases, the intent of the commitment was fulfilled, albeit by other means. In the first case, multiple methods of communications are available and the specified method was shown to be unnecessary by drill performance and was also discussed as possibly detrimental to overall emergency operations communications. The commitment regarding motor-operated valves will be fulfilled by other means as discussed in RIS 2011-03.
While transitioning from an older tracking application to the current system, the licensee identified that some commitments had not been annotated consistently within the licensee's previous tracking system. The licensee completed a review of tracking items to identify the items as commitments within the current tracking system. No commitments were missed as a result.
M. Nazar -2 Should you have any questions regarding this letter, please contact me by phone at (301) 415-2788 or via email at Tracy.Orf@nrc.gov.
Sincerely, IRA!
Tracy J. Orf, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-335 and 50-389
Enclosure:
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
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