ML14141A306
| ML14141A306 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/05/2014 |
| From: | Joel Wiebe Plant Licensing Branch III |
| To: | Pacilio M Exelon Generation Co |
| Joel Wiebe, NRR/DORL 415-6606 | |
| References | |
| TAC MF3090, TAC MF3091 | |
| Download: ML14141A306 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 J un e 5 , 20 14 Mr. Michael J. Pacilio Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION , UNITS 1 AND 2- AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MF3090 and MF3091)
Dear Mr. Pacilio:
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's 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 Braidwood Station 's commitment management program was performed at the Braidwood Station site during the period of December 16 and 17, 2013. The NRC staff concludes , based on the audit, that Braidwood Station has implemented NRC commitments on a timely basis, and has implemented an effective program for managing NRC commitment changes.
Details of the audit are set forth in the enclosed audit report.
M. Pacilio If you or your staff has any questions about the audit, please contact me at (301) 415-6606.
Sincerely, oel S. Wiebe, Senior Project Manager Plant Licensing 111-2 and Planning and Analysis Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. STN 50-456 and STN 50-457
Enclosure:
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 REGULATORY COMMITMENTS BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457
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, 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 by a licensee to take a specific action by a certain date and submitted in writing on the docket to the NRC.
The NRC's 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 Braidwood Station Commitment Management Program was performed at the Braidwood Station site during the period December 16 and 17, 2013. The audit reviewed commitments made since the previous audit on October 21 , 2010.
NRR guidelines direct the 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 the Agencywide Document Access and Management System (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 and Technical Specifications (TSs) .
Fulfillment of these comm itments 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 all commitments sampled were implemented as committed or were being tracked to appropriately implement at a future date.
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 the Braidwood Station is contained in LS-AA-11 0, Revision 10, dated March 5, 2013, and LS-AA-11 0-1001 , Revision 7, dated March 6, 2013.
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 that the licensee's procedures were consistent with the guidance in NEI 99-04 for commitment tracking, commitment change process , and reporting requ irements .
Based on the sample of commitments reviewed , the NRC staff determined that the licensee followed its procedures.
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. None of the commitments in the sample were determined to be 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 the commitments selected for the audit sample , all license amendment safety evaluations (SEs) , exemptions , and relief .request SEs 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.
None of the license amendment SEs, exemptions, and relief request SEs issued for Braidwood Station since the last audit contained misapplied commitments as described above.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that Braidwood Station has implemented NRC commitments on a timely basis , and has implemented an effective program for managing NRC commitment changes .
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Murtaza Abbas Principal Contributor: Joel Wiebe Date of issuance: June 5, 20 1 4
Attachment:
Summary of Audit Results
AUDIT
SUMMARY
IMPLEMENTATION OF COMMITMENTS:
Commitment Documents Reviewed Comments 00635472-01-00 Revised RP-AA-210 Dosimetry Issue, Verified commitment properly Weighting Factors and Usage and Control, Revision implemented.
Dosimetry Placement 22 01164233-01-00 Elimination Action Request (AR) Verified commitment change of Commitment to change 01164233 properly implemented.
procedure BWHP 4006-56, Torque Switch Replacement 01285808-01-00 Delete AR 01285808 Verified commitment change Requirements Associated with properly implemented Monthly Operability of the Component Cooling Water Pump 01340903-01 Submit to AR 01340903 Verified commitment properly NRC Flaw Evaluations during implemented A1R16 01340903-02 Submit to AR 01340903 Verified commitment properly NRC Flaw Evaluations during implemented examinations covered by Relief Request 13R-08 01351560-06 Monitor for AR 01351560 Verified commitment properly tube slippage in A2R 16 Work Order 01439803 01 implemented 01351560-08 Application AR 01351560 Verified commitment properly of Leakage Factor in Work Order 01439803 01 implemented Preliminary A2R 16 Assessments 01351560-09 Application AR 01351560 Verified commitment properly of Leakage Factor in Final Work Order 01439803 01 implemented A2R 16 Assessments Attachment
- ML14141A306 OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC LPL3-2/PM NAME JWiebe SRohrer TTate JWiebe DATE 6/2/14 6/5/14 6/5/14 6/5/14