ML14022A112
| ML14022A112 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/29/2014 |
| From: | Audrey Klett Plant Licensing Branch II |
| To: | James Shea Tennessee Valley Authority |
| Klett A DORL/LPL2-2 301-415-0489 | |
| References | |
| TAC MF3081, TAC MF3082 | |
| Download: ML14022A112 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37 402-2801 January 29, 2014
SUBJECT:
SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2-AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MF3081 AND MF3082)
Dear Mr. Shea:
Every 3 years, the U.S. Nuclear Regulatory Commission (NRC) staff audits a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC." This office instruction provides the NRC staff and its stakeholders with guidance on managing regulatory commitments and ensures a common understanding of the handling of regulatory commitments made to the NRC staff by licensees for commercial nuclear power reactors.
The NRC staff audited the Tennessee Valley Authority's (the licensee's) commitment management program during the period of December 16 - 20, 2013. The NRC staff concluded that the licensee implemented its commitments on a timely basis, and the licensee implemented an effective program for managing commitment changes. The enclosed audit report contains the details of the audit.
Docket Nos. 50-327 and 50-328
Enclosure:
Audit Report cc w/encl.: Distribution via Listserv Sincerely, Audrey L. Klett, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SEQUOYAH NUCLEAR PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-327 AND 50-328
1.0 INTRODUCTION AND BACKGROUND
On September 16, 2013, the Office of Nuclear Reactor Regulation (NRR) of the U.S. Nuclear Regulatory Commission (NRC) issued Revision 5 of NRR Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13193A358). LIC-105 provides NRR staff guidance on managing regulatory commitments and ensures a common understanding of the handling of regulatory commitments. The guidance is consistent with the Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes" (ADAMS Accession No. ML003680088), which the NRC staff found acceptable as described in Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff' (ADAMS Accession No. ML003741774). 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.
LIC-1 05 requires that every 3 years, NRR project managers (PMs) 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 and the licensee's program for managing changes to its commitments. The audit also determines whether any commitments were misapplied (e.g., whether NRC staff accepted licensee-proposed commitments rather than the necessary regulatory requirement or obligation).
2.0 AUDIT PROCEDURE AND RESULTS The NRR PMs audited Tennessee Valley Authority's (TVA's, the licensee's) commitment management program at the Sequoyah Nuclear Plant (SQN) during an on-site visit from December 16 to 20, 2013. The NRR PMs reviewed commitments made by TVA since the previous NRC audit report dated December 30, 2010 (ADAMS Accession No. ML103610353),
as corrected by letter dated January 19, 2011 (ADAMS Accession No. ML110030328). The audit consisted of verifying the licensee's implementation of its commitments and the licensee's program for managing changes to its commitments and determining whether any commitments were misapplied.
2.1 Verification of Licensee's Implementation of Commitments 2.1.1 Audit Scope The NRR PMs reviewed a sample of about 40 commitments to determine whether the licensee implemented commitments it made to the NRC and captured commitments in an effective program for future implementation. The audit focused on regulatory commitments made in writing to the NRC as part of licensing actions or activities. The NRR PMs reviewed closed Enclosure commitments to verify that the licensee properly implemented them. The NRR PMs also reviewed open commitments to confirm the licensee properly documented, tracked, and scheduled them for implementation. The NRR PMs reviewed documents generated by processes in effect during the scope of the audit and other documents related to commitments.
The NRR PMs did not audit commitments made in licensee event reports, responses to notices of violations, confirmatory orders, confirmatory action letters, or as part of SQN's current license renewal effort if other NRC processes (e.g., NRC's Reactor Oversight Process inspection procedures) prescribed separate followup for these items.
2.1.2 Audit Results The NRR PMs concluded that the licensee appropriately implemented the commitments it made to the NRC. The NRR PMs reviewed licensee correspondence, procedure changes, design change packages, and work orders that the licensee created or revised because of commitments made to the NRC and found that the licensee created or changed these documents in accordance with the commitments. The NRR PMs found that the licensee's commitment tracking program (i.e., Maximo) captured the regulatory commitments identified by the NRC and licensee staff prior to the audit. The attachment to this report summarizes the sample of licensee commitments audited by the NRR PMs and the status of those commitments as of the end of the audit. This attachment does not include all commitments the licensee made to the NRC.
The NRR PMs noted that the licensee's commitment implementation procedure, NPG-SPP-03.3, "NRC Commitment Management," Revision 3, identified personnel authorized to make commitments. The authorized personnel did not include any third parties (e.g., NEI).
The NRR PMs identified a few minor issues, such as a missing form for entering commitments in Maximo, an incorrect due date, and discrepancies between the original commitment language and that captured in Maximo. TVA staff corrected the issues or entered them into its corrective action program. The NRR PMs noted that the licensee's software program for managing commitments has some limitations that cause inefficiencies (e.g., inability to print records, perform queries and other database functions, and update records after commitment closure is recorded). The NRR PMs also observed that various licensee staff have differing views about the required timeliness noted on commitment closure forms regarding the commitment completion date (i.e., whether the commitment is considered closed when the work is completed versus when TVA's licensing staff reviews and signs the completion form). The NRR PMs noted that if TVA's licensing staff identifies, after the commitment due date, issues with the actions taken, that TVA could be vulnerable to missing the commitment due dates. The licensee captured these issues in its corrective action program as the following service request (SR) and problem evaluation reports (PERs):
SR 768437-Commitment Management Process Improvement Recommendations PER 825142-Evaluation Guidance for Commitment Closure Completion PER 825143-SQN Commitment Audit Observation PER 825188-Commitment Closure Form Included Wrong Due Date 2.2 Verification of Licensee's Program for Managing Commitment Changes 2.2.1 Audit Scope The NRR PMs reviewed the licensee's procedures and program for managing commitment changes to verify the licensee established adequate controls for modifying or deleting commitments made to the NRC. The NRR PMs compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04. The NRR PMs staff also reviewed modified or deleted commitments that the licensee reported and did not report to the NRC. The NRR PMs reviewed the licensee's commitment summary reports provided to the NRC on December 13, 2011, and July 1, 2013 (ADAMS Accession Nos. ML11350A233 and ML13189A134, respectively). The NRR PMs staff also determined whether the licensee's commitment management system ensured traceability of commitments following initial implementation to verify that the licensee evaluated proposed changes to affected design features or operating practices in accordance with its commitment change control process.
2.2.2 Audit Results The NRR PMs reviewed the evaluation forms for the commitment changes that the licensee reported and did not report to the NRC and found no issues. The NRR PMs concluded that the licensee established adequate controls for modifying or deleting commitments made to the NRC. The NRR PMs concluded that the licensee modified or deleted commitments in accordance with the guidelines in NEI 99-04. The NRR PMs staff also determined that the licensee's commitment management system ensured traceability of commitments following initial implementation.
The NRR PMs noted that the licensee's staff performed a self-assessment of its commitment management audit, which demonstrates positive behavior for identifying and correcting issues related to regulatory commitment management. The NRR PMs provided the licensee with feedback on separately entering multiple commitments from the same correspondence into Maximo for easier tracking. The NRR PMs also provided the licensee with feedback on ensuring adequate communications between the site and TVA's corporate office to ensure all commitments are captured in Maximo and assigned to the site.
2.3 Determination of Misapplied Commitments 2.3.1 Audit Scope Prior to the on site audit visit, the NRR PMs reviewed license amendment safety evaluations, exemptions, and relief request safety evaluations issued to the licensee during the previous 3 years to determine if the documents contained any misapplied commitments.
2.3.2 Audit Results The NRR PMs did not identify any misapplied commitments in licensing actions from the past 3 years. However, the licensee identified that in the NRC's cover letter and safety evaluation dated September 28, 2007 (ADAMS Accession No. ML072420043), regarding temperature and level limits of the ultimate heat sink, the NRC staff characterized some licensee statements as regulatory commitments. However, the licensee identified only one of the four statements in the cover letter as a regulatory commitment made in writing within the licensee's correspondence to the NRC. The NRC staff's safety evaluation appeared to rely on these statements and commitments to form its conclusions for approving the amendment; therefore, the NRR PMs identified these statements and commitments as misapplied commitments. The NRR PMs confirmed that the licensee implemented these statements and commitments. Therefore, the misapplied commitments did not result in adverse impacts. The NRC staff concluded that no further action is required with respect to these misapplied commitments.
3.0 CONCLUSION
Based on the audit results, the NRC staff concludes that the licensee implemented commitments in a timely basis, adequately tracked commitments for future implementation, and implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Zachary Kitts, SQN Site Licensing Engineer Principal Contributors: Audrey Klett, NRR, Farideh Saba, NRR
Attachment:
Summary of Audited Commitments
Audited Commitments Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 1
10293002 11/06/09 TVA will be in full compliance with 09/24/12 CLOSED Completed 09/17/12.
10 CFR 73.55(e)(7)(i)(C) and 10 SQN has completed the build of a CFR 73.55(i)(3)(vii) for Sequoyah new remote monitoring system Nuclear Plant by September 24, and the installation of a new 2012.
access control system and installation of a new uninterruptible power supply.
2 111702899 10/11/08 Response to NRC GL 2008-01:
TBD OPEN Due date dependent on NRC TVA will evaluate adopting the approval of the TSTF. TVA might revised ISTS SR 3.5.2.3 (NUREG revise the commitment to state 1431) within 6 months of NRC "evaluate adoption of TSTF" approval of the traveler.
instead of adoption of just the SR.
3 111743796 09/08/09 TVA will revise the UFSAR during 06/24/11 COMPL Completed 12/14/11 with the update following (i.e.,
submittal of UFSAR. The implementation of the proposed closed) licensee's commitment due date TSC.
in the system was arbitrary.
4 112302028 06/01/11 (LAR to Use Methodology 10/22/12 COMPL Completed 11/2/12. Licensee described in Technical Report No.
provided training attendance, SQN2-SGR-TR3, Alternate Rebar qualifications records, lesson Splice - Bar-Lock Mechanical plans, and work packages.
Splices; Withdrawal of Request.)
For the U2 SG replacement activities, members of each splicing crew involved in installation activities will be trained and qualified to install the Bar-Lock Model 6L and Model 8L couplers.
Attachment
- A2-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 5
112999193 12/22/11 TV A will complete installation of 12/31/12 CLOSED Completed 11/20/12 with drain flow chamber modification installation of Modification by 12/31/12.
DCN 22429.
6 113187391 01/27/12 Training will be conducted after N/A COMPL Commitment withdrawn on the work implementing documents 06/07/12 when the licensee supporting implementation of the withdrew its amendment request.
amendment request have been prepared and/or revised and prior to opening either of the 18 inch Shield Building dome hatches.
7 113187505 01/27/12 Work implementing documents N/A COMPL Commitment withdrawn on supporting implementation of 06/07/12 when the licensee amendment request will be withdrew its amendment request.
prepared and/or revised prior to opening of either the 18-inch Shield Buildin_g dome hatches.
8 113187575 01/27/12 Procedures supporting N/A COMPL Commitment withdrawn on implementation of the amendment 06/07/12 when the licensee request will be prepared and/or withdrew its amendment request.
revised prior to opening of either the 18-inch Shield Building dome hatches.
9 113187908 01/27/12 Training will be conducted after N/A COMPL Commitment withdrawn on the procedures supporting 06/07/12 when the licensee implementation of the amendment withdrew its amendment request; request have been prepared however, licensee conducted the and/or revised and prior to training as of 05/16/12.
opening either of the 18-inch Shield Building dome hatches.
-A3-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 10 113457849 09/29/11 Appendix A of the licensee's 10/15/12 COMPL Completed 1 0/30/12. These 09/29/11 submittal contains commitments were added as multiple (11) commitments.
conditions the operating license (as Appendix C) with AMD #330.
11 113636507 06/13/12 Commitment 2 of the 06/13/12 08/10/12 CLOSED Completed 08/10/12 with letter.
submission of amendment request.
i 12 113636887 06/13/12 Commitment 4 of the 06/13/12 08/31/12 CLOSED Completed 08/28/12 with letter.
development and performance of procedure.
13 113636972 06/13/12 Commitment 5 of the 06/13/12 08/31/12 CLOSED Completed 08/28/12 with letter.
development and performance of procedure.
14 113637034 06/13/12 Commitment 6 of the 06/13/12 08/31/12 CLOSED Completed 08/31/12 with letter.
completion of sensitivity analysis.
15 113637349 06/13/12 Commitment 7 of the 06/13/12 08/31/12 CLOSED Completed 08/29/12 with letter.
issuance and performance of inspection procedure.
16 113637486 06/13/12 Commitment 10 of the 06/13/12 03/31/13 CLOSED Completed 04/01/13. The letter.
modification was installed within the due date.
17 113637539 06/13/12 Commitment 11 of the 06/13/12 03/31/13 CLOSED Completed 04/01/13. The caps letter.
were permanently installed near the penetrations within the due date.
18 113637788 06/13/12 Commitment 12 of the 06/13/12 07/19/13 COMPL Completed 07/19/13 with 04/29/13 letter.
submittal of letter, but the commitment package was signed out 2-3 months after the due L_
date.
-A4-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 19 113637975 06/13/12 Commitment 13 of the 06/13/12 10/31/15 OPEN letter.
20 113638072 06/13/12 Commitment 14 of the 06/13/12 10/31/15 OPEN letter.
21 113638235 06/13/12 Commitment 15 of the 06/13/12 10/31/15 OPEN letter.
22 113638294 06/13/12 Commitment 16 of the 06/13/12 10/31/15 OPEN letter.
23 113646268 06/25/12 NRC Confirmatory Action Letter 10/28/12 CLOSED Completed 10/30/12 with (NRC) dated 06/25/12 requested, submittal of letter to the NRC.
regarding commitment 6 of the 06/13/12 letter, that the licensee provides a summary of the results of TVA's analysis to the NRC within 60 days after its completion.
24 113646311 6/25/12 NRC Confirmatory Action Letter 10/31/15 OPEN (NRC) dated 06/25/12 requested NRC's NRR Director be notified in writing when the action in the CAL are completed.
25 114071645 10/26/12 An update of the planned ITS 03/31/13 COMPL Completed with 03/28/13 conversion application and submittal of letter.
ultimate heat sink LAR submittals and associated engineering activities to support shutdown board preventive maintenance effort will be included in the LAR submittal letter or by separate letter by 3/31/13.
- A5-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 26 114080689 10/30/12 TVA will evaluate breach initiators 01/18/13 COMPL Completed with 01/18/13 and submit a report summarizing submittal of letter.
the results of these evaluations by 01/18/13.
27 114498799 03/12/13 TVA will provide NRC a schedule 06/30/13 CLOSED Completed with submittal of of modifications to the SQN and 7/1/131etterto NRC.
WBN plants flood mode spool pieces by June 30, 2013 (extended to July 1, 2013}.
28 114498824 03/12/13 TV A will present a proposed 06/30/13 CLOSED Commitment was completed on methodology for spatial scenarios 06/27/13 with a meeting to the NRC by 06/30/413.
presentation. The commitment completion was signed on 07/02/13 and by a letter dated 07/02/13.
29 114498845 03/12/13 TVA will provide details of the 8/29/13 CLOSED Completed 08/29/13 with planned drill to the revised flood submittal of letter to NRC.
mode operation abnormal operating procedure (AOP) N.03 by August 29, 2013.
30 114498876 03/12/13 TVA will perform a drill to the 12/31/13 COMPL Completed on 1 0/03/13. An revised flood mode operation external drill report was done on abnormal operating procedure 9/18/13.
(AOP) N.03 by December 31, 2013.
31 114498918 03/12/13 TVA will provide the flooding 03/12/15 OPEN 05/29/13 hazard reevaluation report to the NRC by March 12, 2015.
-A6-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
letter Date 32 114554032 03/28/13 Submit letter to NRC with updated 09/30/13 CLOSED Completed with letter dated status of ITS, UHS LAR, and 09/30/13.
Engineering activities supporting shutdown board preventive maintenance.
33 114615777 04/16/13 TVA will construct a flood mode 06/30/15 OPEN hardened structure that will meet or exceed NEI 12-06 as described for Milestone 1 in the Table in of the commitment letter by June 2015 (Milestone 1 of ; Commitment 1 in is linked to this milestone).
34 114618058 04/16/13 TVA will install flood mode 12/31/15 Open hardened 3.0 MWe Diesels (one per operating unit) designed to provide extended coping in accordance with NEI 12-06 guidance as described for Milestone 2 in the Table in of the commitment letter by December 2015.
(Milestone 2 of Enclosure 1; Commitment 1 in enclosure 2 is linked to this milestone).
-A7-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 35 114618583 04/30/13 TVA will complete a 12/31/14 OPEN comprehensive evaluation of commercial grade dedicated items installed between September 1995 and November 2011 for the operating fleet, and correct any identified deficiencies by December 31, 2014.
36 114618954 04/16/13 TVA will install a hardened 12/31/16 OPEN enhanced flood mode system for decay heat removal as described for Milestone 3 in the Table in of the commitment letter by December 2016.
(Milestone 3 of Enclosure 1 ;
Commitment 1 in enclosure 2 is linked to this milestone).
37 114620131 04/16/13 TVA will install a hardened 12/31/16 OPEN enhanced flood mode RCS makeup system as described for Milestone 4 in the Table in of the commitment letter by December 2016 (Milestone 4 of Enclosure 1; Commitment 1 in enclosure 2 is linked to this milestone).
- A8-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 38 114621526 04/16/13 TVA will provide periodic written 12/31/16 OPEN updates to the NRC regarding progress of the improved flood mitigation system project by the last day of March. June.
September and December of each year until the project is completed, beginning with the first written progress report to be filed by June 30, 2013 (Commitment 2 of ).
39 114751968 05/16/13 TV A will complete the review of 06/20/14 OPEN the Safety Evaluation Report and document adherence to the Limitations and Conditions contained in Section 4.0 in the appropriate TVA calculations and design documents and will submit the results of this effort to NRC by June 20, 2014.
40 115088940 09/30/13 Submit letter to NRC with updated 03/28/14 OPEN status of ITS, UHS LAR, and design activities supporting implementation of periodic shutdown board preventive maintenance.
-A9-Item SQN ID#
Commitment Summary of Commitment Due Date Status Method of Closure No.
Letter Date 41 115126899 09/30/13 TV A to address the RAI related to 03/12/15 OPEN the review of the potential breaches of HESCO flood barriers and earthen embankments affecting the updated hydro analysis results with the Hazard Reevaluation Report. The due date for the HRR is 03/12/15.
42 115251669 04/30/13 TVA will provide the NRC with 12/31/14 OPEN periodic written updates regarding progress of the project by the last day of July, October, January, and April of each year until the project is completed, beginning with the first written report to be filed by July 31,2013.
43 NC009000 02/23/09 Commitment is related to NRC TBD OPEN Due date being re-established.
3001 GL 2004-02.
Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37 402-2801 January 29, 2014
SUBJECT:
SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2-AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MF3081 AND MF3082)
Dear Mr. Shea:
Every 3 years, the U.S. Nuclear Regulatory Commission (NRC) staff audits a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-1 05, "Managing Regulatory Commitments Made by Licensees to the NRC.". This office instruction provides the NRC staff and its stakeholders with guidance on managing regulatory commitments and ensures a common understanding of the handling of regulatory commitments made to the NRC staff by licensees for commercial nuclear power reactors.
The NRC staff audited the Tennessee Valley Authority's (the licensee's) commitment management program during the period of December 16-20, 2013. The NRC staff concluded that the licensee implemented its commitments on a timely basis, and the licensee implemented an effective program for managing commitment changes. The enclosed audit report contains the details of the audit.
Docket Nos. 50-327 and 50-328
Enclosure:
Audit Report cc w/encl.: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrDoriLPL2-2 LPL2-2 R/F RidsNrrLABCiayton ADAMS ACCESSION NO* ML14022A112 OFFICE LPL2-2/PM LPL2-2/PM NAME A Klett FSaba DATE 1/28/14 1/28/14 Sincerely, IRA/
Audrey L. Klett, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsRgn2MaiiCenter RidsAcrsAcnwMaiiCenter RidsNrrPMSequoyah LRegner LPL2-2/LA LPL2-2/BC LPL2-2/PM BCiayton JQuichocho AKiett 1/27/14 1/28/14 1/29/14 OFFICIAL AGENCY COPY