ML14071A233

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Audit of the Licensee'S Management of Regulatory Commitments
ML14071A233
Person / Time
Site: Pilgrim
Issue date: 04/11/2014
From: Nadiyah Morgan
Plant Licensing Branch 1
To: Dent J
Entergy Nuclear Operations
Morgan N
References
TAC MF3117
Download: ML14071A233 (9)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April11, 2014 John Dent, Jr.

Site Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 SUBJECT PILGRIM NUCLEAR POWER STATION -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF3117)

Dear Sir or Madam:

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," Revision 0 contains acceptable guidance for controlling regulatory commitments. The 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 Pilgrim Nuclear Power Station (Pilgrim) commitment management program was performed at Pilgrim during the period December 10 - 11, 2013. Details of the audit are set forth in the enclosed audit report. Based on the results of the audit, the NRC staff has concluded that the Entergy Nuclear Operations, Inc. staff has implemented NRC commitments on a timely basis and has established a procedure for managing NRC commitment changes, based on NEI 99-04 guidance.

J. Dent, Jr. If you have any questions regarding this issue, please contact me at (301) 415-1016.

Sincerely, I

//

/ ~ /

N~adiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293

Enclosure:

As stated cc w/encl & attachment: 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 PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293

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," Revision 0 contains acceptable guidance for controlling regulatory commitments. The 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 describes a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee by a certain date 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 Pilgrim Nuclear Power Station (Pilgrim) commitment management program was performed at Pilgrim during the period December 10 - 11, 2013. The audit reviewed commitments made since the previous audit during the period December 14-15, 2010.

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 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 the Agencywide Document Access and Management System 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 and Technical Specifications. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

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.

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.

2.1.2 Audit Results The attached Audit Summary provides details of the audit and its results. The NRC staff found that Entergy Nuclear Operations, Inc. (Entergy, the licensee) has implemented the sample of commitments made to the NRC, as part of past licensing actions and activities. The commitments were implemented in a manner that satisfied both the action committed to and the overall intent of the commitment.

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. This portion of the audit also compares the licensee's administrative controls to the guidance in NEI 99-04 and assesses the licensee's implementation of its administrative controls.

2.2.1 Audit Results The administrative controls used at Pilgrim are contained in Entergy's Procedure, EN-LI-11 0, Revision 6, "Commitment Management Program." The NRC staff found that the licensee's procedure fully implements the guidance in NEI 99-04.

The licensee did not modify or delete any commitments made to the NRC. Therefore, the NRC staff was not able to evaluate the licensee's effectiveness in implementing its procedure, EN-LI-110 for managing NRC commitment changes.

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 NRC staff did not find 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 the facility since the last audit were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above.

The NRC staff did not find any misapplied commitments in the license amendment, exemption, or relief request safety evaluations that have been issued for Pilgrim since the last audit.

3.0 CONCLUSION

Based on the results of the audit, the NRC staff has concluded that the licensee's staff has implemented NRC commitments on a timely basis and has established a procedure for managing NRC commitment changes, based on NEI 99-04 guidance.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Walt Lobo Bob Byrne Principal Contributors: Nadiyah Morgan Ben Beasley Date: April 11, 2014

AUDIT

SUMMARY

IMPLEMENTATION OF COMMITMENTS:

The NRC staff used Entergy's procedures, EN-LI-11 0, Revision 6, Commitment Management Program and EN-LI-106, Revision 12, NRC Correspondence to evaluate the management and implementation of the following commitments.

CA- Condition Action CR - Condition Report lAS - Integrated Asset Suite LCO - Limiting Condition of Operation PCRS - Paperless Condition Reporting System By letter dated April 29, 2013, the licensee

  • PCRS printout: LR-LAR-2012-118, CA committed to respond to the NRC Title 10 of the Number 33 Code of Federal Regulations 50.54(f) Request for
  • NEI April 9, 2013 Proposed Path Information Letter regarding Recommendations Forward for NTTF Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task Force 2.1: Seismic Reevaluations Letter Review of Insights from the Fukushima Dai-ichi Accident.

By CO"""""itt*"'l'ld~l'\;

(Code Code By letter dated November 27, 2012, the licensee

  • PCRS printout: LR-LAR-2012-00118, committed to perform walkdowns for equipment CA Number 24 that could not be inspected as identified in Section
  • Attachments J and K of the Seismic 6.3 of its Seismic Walkdown Report by May 31, Walkdown Report, PNPS-CS 2013. 00001 Revision 1

~~~~~:;9 By letter dated November 27, 2012, the licensee

  • PCRS printout: LR-LAR-2012-00118, committed to resolve the potentially adverse CA Number 26 seismic conditions as identified in Section 8.2 of

Attachment

By letter dated August 3, 2012, the licensee

  • LC0-1-ACT-12-0095 report regarding the inoperability of the Reactor
  • Pilgrim Procedure 3.M.2-19, "High Range Effluent Monitor Calibration,"

Revision 23

  • Entergy Procedure EN-HU-1 02, "Human Performance Traps and Tools" Pre-Job B Checkl Revision 11 By letter dated February 15, 2011, the licensee
  • Closeout letter No. 2.11.026 dated committed to revise Section 4.3, "Defense-In- April4, 2011 Depth Protective Strategies," of the Pilgrim Cyber
  • Section 4.3, "Defense-In-Depth Security Plan in accordance with its RAI Protective Strategies," of the Pilgrim responses by a date to be determined. Secu Plan MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS:

The licensee did not modify or delete any commitments made to the NRC.

ML14071A233 OFFICE LPL 1-1/PM LPL 1-1/LA LPL 1-1/BC NAME NMorgan KGoldstein BBeasley DATE 03/19/2014 03/19/2014 04/11/2014

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