ML13072A139
| ML13072A139 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/04/2014 |
| From: | John Lamb Plant Licensing Branch 1 |
| To: | Ossing M, Walsh K NextEra Energy Seabrook |
| Lamb J | |
| References | |
| TAC MF1318 | |
| Download: ML13072A139 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 4, 2014 Mr. Kevin Walsh, Site Vice President c/o Michael Ossing Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 0387 4
SUBJECT:
SEABROOK STATION, UNIT 1 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF1318)
Dear Mr. Walsh:
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 regulatory commitments are being effectively implemented.
An audit of Seabrook Station, Unit 1 (Seabrook) commitment management program was performed at NRC Headquarters during the period of March - November 2013 and at the Seabrook site on March 26, March 27, November 18, and November 19, 2013. The NRC staff concludes, based on the audit, that: (1) Seabrook has implemented NRC commitments on a timely basis, and (2) Seabrook has implemented an effective program for managing NRC commitment changes.
K. Walsh Details of the audit are set forth in the enclosed audit report.
- ~
hn G. Lamb, Acting Chief ant Licensing Branch 1-2 ivision of Operating Reactor Licensing ffice of Nuclear Reactor Regulation Docket No. 50-443
Enclosure:
Audit Report cc: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SEABROOK STATION. UNIT 1 DOCKET NO. 50-443
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, 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 regulatory commitments are being effectively implemented. An audit of the Seabrook Station, Unit 1 (Seabrook) commitment management program was performed at NRC Headquarters during the period of March- November 2013, and at the Seabrook site on March 26, March 27, November 18, and November 19, 2013. The audit reviewed commitments made since the previous audit on December 29, 2010 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML103570180).
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
2.1 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 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 (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 table contains a list of those documents that were selected for additional review during this audit.
The NRC staff reviewed the report generated by the licensee's tracking program and associated documentation of the selected representative sample items. Additionally, the NRC staff's review of the commitment list found that the licensee's commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant procedures that had been revised or implemented as a result of commitments made by the licensee to the NRC. The NRC staff
also reviewed items originally added to the commitment tracking system, but were later modified. In these cases, the NRC staff verified that the licensee correctly applied the NEI 04 definition in determining that they were not commitments.
The NRC staff noted that, where appropriate, procedures have annotations to refer to commitments. These annotations serve to prevent future procedure changes from inadvertently deleting or altering an item without having gone through the commitment change process.
Additionally, the annotations specifically refer to its related commitment allowing for enhanced traceability.
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 Seabrook is contained in Licensee's Procedure LIAA-101-1005, "NRC Commitment Management." 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.
The NRC staff found commitments contained in Attachment 2 to a letter dated Apri129, 2009 (ADAMS Accession No. ML091200065), regarding the Delta Protection Air Suits. These commitments were entered into an Action Request (AR) 00200249. The NRC staff verified that procedures HD0965.07, "Air Supplied Respiratory Protection Equipment and Distribution System," and HD0965.12, "Respiratory Equipment Issue and Use," were revised.
The NRC staff found in the H* Program amendment, dated September 10, 2012 (ADAMS Accession No. ML12178A537), regarding technical specification (TS) 6.7.6.k that the licensee committed in letter, dated April 10, 2012, to monitor for tube slippage as part of the steam generator inspection program. Under the license amendment, TS 6.8.1.7.k will require that the results of slippage monitoring be included as part of the 180-day report, which is required by TS 6.8.1.7. In addition, TS 6.8.1.7.k requires that should slippage be discovered, the implications of the discovery and corrective action shall be included in the report. The NRC staff found that slippage is not expected to occur for the reasons discussed in the safety evaluation. In the unexpected event it should occur, it will be important to understand why it occurred so that the need for corrective action can be evaluated. The NRC staff concluded the commitment to monitor for slippage and the accompanying reporting requirements were acceptable. This commitment is not part of the Seabrook license, which is consistent with the fact that details of how condition monitoring and operational assessments are performed are generally not included as part of the operating license, including the TSs. Extensive industry guidance on conducting condition monitoring and operational assessments is available as part of the industry NEI 97-06 initiative (ADAMS Accession No. ML111310708). This commitment ensures that plant procedures address the above leakage factor issue as they do industry guidelines. The NRC staff verified that procedure SGRE Revision 16, "Steam Generator Management Reference," was revised.
The NRC staff found as part of relief request N-716, dated June 21, 2012 (ADAMS Accession No. ML121320552), that the licensee made a commitment to perform a modification that would limit the postulated maximum fire protection break flow rate in the Control Building, and thus reduce the flood risk from the Fire Protection pipe segments to less than 1 E-06/yr. The NRC staff verified that the modification package, EC-272184, "Fire Protection Piping Restriction Orifice," was completed.
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. The audit did not reveal any misapplied commitments.
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.
A review of all the licensing actions since December 2010 did not reveal any misapplied commitments.
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 acceptable program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
- Michael Ossing
- Victoria Brown
- Paul Willoughby Principal Contributor: John G. Lamb Date: January 4, 2014
Attachment:
Summary of Audit Results
TABLE -
SUMMARY
OF AUDIT RESULTS LIST OF DOCUMENTS REVIEWED I Item I Source--T- Commitment I Timeframe I Comments I 1 Action Request (AR) Contained in Attachment 2 of the letter dated April 28, 2009 Complete. Completed. Procedures 00200249 - Delta (ML091200065}. 03/31/11 HD0965.07 and Protection Air Suit - HD0965.12 were revised.
6/25/09 2 AR 00200907 - Generic Tracking development and submittal of responses to NRC Complete. None.
Letter (GL) 2004 request for additional information (RAI). 06/06/11 0706/09 3 AR 00204720- Limited See 28 below. Complete. See 28 below.
Steam Generator (SG) 10/28/09 Tube Inspections-09/04/09 4 AR 00217436- Nuclear Incorporate the final recommendations from the NEI EP/Security Complete. None.
Energy Institute (NEI) Task Force after endorsement by the NRC and Federal 07/20/11 Emergency Emergency Management Agency.
Preparedness (EP)/
Security Task Force-02/23/10 5 AR 00222456 - Tracking procedures describing compensatory measures. Complete. See 33 below.
Procedures for 12/07/10 Containment Enclosure Emergency Air Cleanup System (CEEACS)
License Amendment Request (LAR) 10 05/03/10 6 AR 00223189- NextEra will have written procedures available describing Complete. See 33 below.
Procedures for comp compensatory measures. 09/08/10 measure for CEEACS LAR 10 05/13/1 0 7 AR 00574412- Submit Submit report of 10 CFR 72.48 evaluations. Complete. None.
report of 10 CFR 72.48 08/17/12 evaluations - 08/19/1 0 8 AR 00581380 - NextEra will supplement its Cyber Security Plan. Complete. See 24 below.
Supplement Cyber 01/10/11 Attachment
TABLE -
SUMMARY
OF AUDIT RESULTS LIST OF DOCUMENTS REVIEWED I Item I Source - - [- Commitment I Timeframe I -Com-ments- - - ]
Security Plan - 09/22/1 0 9 AR 00593700593745- NextEra commits to perform complete UT pre-service Complete. None.
Complete ultrasonic examination of the subject outlet nozzle to safe end dissimilar 05/10/11 testing (UT) pre-service metal butt weld in OR14.
exam -11/09/10 10 AR 00593752- Submit NextEra will supplement its Cyber Security Plan. Complete. See 24 below.
revised cyber Security 01/10/11 Plan - 11/09/1 0 11 AR 01647856-2012 Track the 2012 annual reports required by tech spec. Complete. None.
Annual Reports required 01/18/13 by tech specs -
05/03/11 12 AR 01670232- Submit Submit the annual 10 CFR 50.46 report. Complete. None.
Annual 10 CFR 50.46 07/17/12 Report - 07/19/11 13 AR 01670233- Submittal of the Annual Material Status Report required by 10 Complete. None.
Submittal of the Annual CFR 74.13. 07/17/12 material Status Report -
07/19/11 14 AR 01705298- Submittal of the Post OR15 Reports. Complete. None.
Submittal of the Post 01/29/13 OR15 Reports-11/10/11 15 AR 01708790- Submittal of the 50.59 Report and UFSAR. Complete. None.
Submittal of the 50.59 04/29/13 Report and Updated Final Safety Analysis Report (UFSAR) -
11/21/11 16 AR 01718010- Issue Issue Control Room Command Function Directive for 2013. Complete. None.
Control Room Command 12/18/12 Function Directive-12/20/11 17 AR 01751164- SG See 28 below. Complete. See 28 below.
TABLE -
SUMMARY
OF AUDIT RESULTS LIST OF DOCUMENTS REVIEWED I Item I Source I Commitment I Timeframe- ] - - - Com-ments - - -I Tube Slip Monitoring- 10/26/12 04/12/12 18 AR 01760072- Submit Perform required annual review in accordance with 10 CFR Complete. None.
10 CFR 50. 75(g) 50.75(g). 02/04/13 Decommissioning Records - 04/16/12 19 AR 01818046- EP Track the milestones and due dates for the EP white finding Complete. None.
95001 Inspection 95001 inspection. 01/09/13 Milestones - 10/30/12 20 AR 01818057- Track the milestones and due dates for the NRC CDBI Complete. None.
Component Design inspection. 03/11/13 Basis Inspection (CBDI) milestones- 10/30/12 21 AR 01857811 -Submit Track submittal letter to register candidates for GFE. Complete. None.
Candidates for General 04/29/13 Fundamentals Exam
{GFE)- 03/19/13 22 Amendment - Relocate No commitments. N/A None.
TS 3.8.4. 1 Class 1E Power Sources-ML110840188-04/29/11 23 Amendment - Remove No commitments. N/A None.
TS 3.4.1 0 Structural Integrity- ML111250388
- 08/22/11 24 Amendment - Cyber There is no commitment; there is a license condition. Complete. None.
Security Plan -
08/23/11 25 Amendment- No commitments. N/A None.
Containment Spray Nozzle - ML113260577
-01/30/12 TABLE-
SUMMARY
OF AUDIT RESULTS LIST OF DOCUMENTS REVIEWED I Item I Source I Commitment I Timeframe I Comments ]
26 Amendment- Leakage No commitments. N/A None.
Detection Instrumentation-ML120030271 -
02/23/12 27 Amendment - Remove No commitments. N/A None. '
TS 3.3.3.5 Remote Shutdown-ML113620228 -
02/28/13 28 Amendment- The licensee committed in letter dated April 10, 2012, to monitor The licensee This commitment is not H*Program TS 6.7.6.k- for tube slippage as part of the SG inspection program. Under revised the part of the Seabrook ML12178A537 - the license amendment, TS 6.8.1.7.k will require that the results "Steam license, which is 09/10/12 of slippage monitoring be included as part of the 180-day report, Generator consistent with the fact which is required by TS 6.8.1.7. In addition, TS 6.8.1.7.k Management that details of how requires that should slippage be discovered, the implications of Reference," condition monitoring and the discovery and corrective action shall be included in the SGRE Revision operational assessments report. The NRC staff found that slippage is not expected to 16. are performed are occur for the reasons discussed in the safety evaluation. In the generally not included as unexpected event it should occur, it will be important to part of the operating understand why it occurred so that the need for corrective action license, including the can be evaluated. The NRC staff concluded the commitment to technical specifications.
monitor for slippage and the accompanying reporting Extensive industry requirements were acceptable. guidance on conducting condition monitoring and operational assessments is available as part of the industry NEI 97-06 initiative (Agencywide Documents and Access Management System Accession No. ML111310708). The above commitment TABLE -
SUMMARY
OF AUDIT RESULTS LIST OF DOCUMENTS REVIEWED I Item I Source I Commitment I Timeframe ] - - - Co-m-ments - I ensures that plant procedures address the above leakage factor issue as they do industry guidelines.
29 Amendment - Cyber There is no commitment; there is a license condition.
Security-ML12237A094 -
11/02/12 30 Amendment- EP No commitments. N/A None.
Emergency Action Level Changes-ML12332A301 -
01/31/13 31 Amendment - Reactor No commitments. N/A None.
Coolant Pump Flywheel
- ML13028A146-04/04/13 32 Amendment - Reactor No commitments. N/A None.
Coolant System Pressure Temperature Setpoints-ML120820510-04/15/13 33 Amendment CEEACS - No commitments. N/A None.
ML113000063 4/23/13 34 Amendment- No commitments. N/A None.
Administrative Changes
- ML13074A760-06/17/13 35 Relief Request N-716 - NextEra internal flood risk assessment SSPSS-2011 identified Complete in As discussed in Section 4 ML121320552- that 4" and 6" diameter Fire Protection piping segments located accordance of the submittal, and 06/21/12 in the Control Building stairwell contributed greater than 1 E- with Section 3.8 of this Safety 06/yr to the core damage frequency. Therefore, NextEra is modification Evaluation, the RIS_B TABLE-
SUMMARY
OF AUDIT RESULTS LIST OF DOCUMENTS REVIEWED
[*Item I Source I Commitment I Timeframe I- - - Corr\merrts- - *
- I committing to a prudent risk management measure to reduce package, EC- program is a living the Fire Protection flooding risk in the Control Building. The 272184, "Fire program. Changes to the modification will limit the postulated maximum fire protection Protection facility or to the break flow rate in the Control Building, and thus reduce the flood Piping Probabilistic Risk risk from the Fire Protection pipe segments to less than 1 E- Restriction Assessment are expected 06/yr. These fire protection piping segments are, therefore, not Orifice." to occur and the included in the RIS_B scope. This modification will be completed licensees periodically prior to implementation of risk-informed inservice inspections. review these changes to ensure the appropriate identification of High Safety Significant piping locations. The NRC staff agrees that a modification to limit the postulated maximum fire protection break flow rate is a prudent risk management measure. The licensee's commitment management program provides sufficient control over the related commitment to perform this modification.
36 Relief Request- 21R-17 No commitments. N/A None.
- ML12144A240-06/04/12 37 Relief Request- 21R-18 No commitments. N/A None.
ML12144A435-06/04/12 38 Relief Request- 21R-19 No commitments. N/A None.
- ML12145A048-06/04/12 39 Relief Request- 21R-20 No commitments. - - -
N/A None. - *- *---
TABLE-
SUMMARY
OF AUDIT RESULTS LIST OF DOCUMENTS REVIEWED Item I Source -T Commitment I Timeframe I Comments I
- ML12145A170-06/04/12 40 Relief Request- 31R2- No commitments. N/A None.
ML120860397- !
06/28/12 41 Relief Request- 31R1 - No commitments. N/A None.
ML120880245 - I 06/27/12 42 Relief Request - N-729- No commitments. N/A None.
I 1 - ML120820333-06/26/12 43 Relief Request- 31R3- No commitments. N/A None.
I ML120740580 -
03/29/12 I 44 Relief Request - No commitments. N/A None.
Alternative ASME I Section XI-ML12185A069-01/14/13
ML13072A139 *via email OFFICE LPL 1-2/PM LPL4-1/LAit LPL 1-2/LA* DORLIDD LPL 1-2/BC (A)
JHughey for KBeckford NAME ABaxter Llund Jlamb Jlamb DATE 12/20/2013 12/12/2013 12/12/2013 01/03/2014 01/04/2014