ML14042A212

Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed November 18-20, 2013

ML14042A212
Person / Time
Site:	Callaway
Issue date:	02/18/2014
From:	Lyon C Plant Licensing Branch IV
To:	Diya F Union Electric Co
Lyon C
References
TAC MF2970
Download: ML14042A212 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 18, 2014 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF2970)

Dear Mr. Diya:

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the 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 that the regulatory commitments are being effectively implemented.

An audit of the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period November 18-20, 2013. Based on the audit, the NRC staff concludes that Union Electric Company (the licensee) has implemented NRC commitments on a timely basis and has implemented its program for managing NRC commitment changes. The details of the results of the audit are set forth in the enclosed audit report.

I appreciate the assistance and support provided by your licensing staff during the audit, particularly Mr. David Brownawell.

F. Diya If you have any questions, please contact me at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

Commitment 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 LICENSEE MANAGEMENT OF REGULA TORY COMMITMENTS UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION AND BACKGROUND

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 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), the 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 that the 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 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, relief requests, 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 the Callaway Plant, Unit 1, commitment management program was performed at the plant site during the period November 18-20, 2013. The audit reviewed commitments made by Union Electric Company (the licensee) since the previous audit on October 13-15, 2010, which were documented in an audit report dated December 21, 201 0 (ADAMS Accession Enclosure

No. ML103540382). The NRR Project Manager also reviewed the licensee's "Cycle 18 Commitment Change Summary Report," dated May 12, 2012, and the "Cycle 19 Commitment Change Summary Report," dated November 21, 2013 (ADAMS Accession Nos. ML12135A435 and ML13326A935, respectively). 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.

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, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in 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, 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 licensee's commitments are tracked in the Commitment Tracking System (CTS) computer database and are managed in accordance with Callaway Plant procedure APA-ZZ-00540, "Commitment Management Program," Revision 017. For this audit, the NRC staff reviewed open and closed regulatory 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 as required by the Callaway Plant. The NRC staff reviewed relevant reports and summary sheets from the computer database and other sources (e.g.,

corrective action documentation, plant procedures, job numbers, night orders, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition, the NRC staff reviewed the licensee's self-assessment

(#201300670) of the Commitment Tracking Program.

Based on the review of reports provided by the licensee as described above and on queries of the CTS database during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis. For this audit, the only open commitments unrelated to license renewal were associated with license Amendment No. 202, dated July 29, 2011 (licensee commitment nos. 50133-50136), and the NRC's safety assessment in response to information request pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.54(f)

Recommendation 9.3, Communications Assessment, dated May 24, 2013 (licensee commitment no. 50252). These were appropriately tracked in CTS. The auditors reviewed commitments closed since the last audit, and no discrepancies were noted.

The auditors also reviewed the corrective actions for deficiencies noted in the last audit and in the licensee's self-assessment, and concluded that the corrective actions were appropriate to address the deficiencies. The auditors noted one deficiency, which was discussed with the licensee staff: Commitment no. 50106 (data trending for over temperature-delta temperature (OTDT), steam generator level, and pressurizer pressure) was closed with no traceable reference in the CTS to how it was closed.

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 Callaway Plant is contained in APA-ZZ-00540, "Commitment Management Program," Revision 017 with accompanying change forms CA 1571, "Commitment Revision, Initiation, Deletion, Request (CRIDR)," and CA2358, "Commitment Evaluation Summary." The auditors 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 auditors also verified 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 procedure APA-ZZ-00540 and its required forms and associated procedures to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.

The NRC staff compared the guidance in the Callaway Plant procedure APA-ZZ-00540 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the Callaway Plant procedure was 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 the Callaway Plant procedure.

Based on the review of the reports provided by the licensee as described above, queries of the CTS database, and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes in accordance with its site procedure is satisfactory.

3.0 CONCLUSION

The NRC staff concludes, based on the audit, that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for managing NRC commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Thomas B. Elwood David Brownawell Principal Contributors: F. Lyon M. Bartlett Date: February 18, 2014

• ML14042A212 OFFICE NRR/DORLILPL4-1/PM NRR/DORLILPL4-1/LA NRR/DORL/LPL4-1/BC NRR/DORLILPL4-1/PM NAME FLyon JBurkhardt MMarkley FLyon DATE 2/18/14 2/13/14 2/18/14 2/18/14