ML14226A395

Audit of the Licensee'S Management of Regulatory Commitments

ML14226A395
Person / Time
Site:	North Anna
Issue date:	08/22/2014
From:	V Sreenivas Plant Licensing Branch II
To:	Heacock D Virginia Electric & Power Co (VEPCO)
Sreenivas V
References
TAC MF4565, TAC MF4566
Download: ML14226A395 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 August 22, 2014 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Boulevard ,

Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2- AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF4565 AND MF4566)

Dear Mr. Heacock:

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 North Anna Power Station commitment management program was performed at the plant site on June 26, 2014. Based on the audit, the NRC staff concludes that Virginia Electric and Power 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, particularly Mr. Jay Leberstien, Mr. Page Kemp and Mr. Tom Shaub.

D. A. Heacock If you have any questions, please contact me at 301-415-2597 or via e-mail at v.sreenivas@ nrc.gov.

Sincerely,

r. V. Sreenivas, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

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 REGULATORY COMMITMENTS NORTH ANNA POWER STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-338 AND 50-339

1.0 INTRODUCTION AND BACKGROUND

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC [Nuclear Regulatory Commission] 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 (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, reliefs, exemptions, etc.)

and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS The regulatory commitment management audit was previously performed at North Anna Power Station, Unit Nos. 1 and 2 (NAPS) on August 8, 2011, covering the period of approximately 3 years. The current audit was performed at NAPS on June 26, 2014, verifying the regulatory commitments made by Virginia Electric and Power Company (the licensee) since the previous audit. "

The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been implemented and (2) verification of the licensee's program for managing changes to NRC commitments.

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.

• 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.). Before the audit, the NRC staff searched ADAMS (Agencywide Documents Access and Management System) for the licensee's sLJbmittals 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 Audit Summary provides details of the audit and its results.

The NRC staff reviewed documents generated by the licensee for the commitments listed in Table 1. After identification, most commitments were managed through the NAPS Central Reporting System. The NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of reviewing the licensee's information, as well as information from other sources, the NRC staff found no reason to differ from the licensee's reported status of the audited commitments. Thus, the NRC staff concludes that the procedure used by the licensee to manage commitments is appropriate and effective.

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 NAPS is contained in "Commitment Management," LI-AA-110, Revision 0. In general, LI-AA-110, Revision 0, follows the guidance of NEI-99-04; it sets forth the need for identifying, tracking, and reporting commitments, and it provides a mechanism for changing commitments. The audit reviewed a sample of commitment changes that included changes that were or will be reported to the NRC. 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.

3.0 CONCLUSION

The NRC staff concludes, based on the above audit: (1) the licensee has generally implemented regulatory commitments on a timely basis, and (2) the licensee has implemented an effective .

program to manage regulatory commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Jay Leberstien, Technical Advisor, Station Licensing, North Anna Power Station, Mineral, VA Tom Shaub, Licensing Management Contact, lnnsbrook Technical Center, Glen Allen, VA Principal Contributor: V. Sreenivas

Attachment:

Summary of Audit Results

North Anna Power Station Commitments March 1, 2011 through June 26, 2014 CAlLA Ltr No. Date Commitment Status/Comments I Number S/G Nozzle Weld Overlays-LA241, 244 &

11-120 3/30/11 1. Provide analysis summaries prior to Mode 4.12-308 245

2. Provide exam results within 14 days of completion.12-326 I I

GL :2004 Recalculate debris generation after industry 11-083 4/27/11 testing. Provide schedule for testing and or modifications, as LA2536 & 2537

• Closed to 13-325 necessary. I I ISFSI Cask misleading- Submit TS exemption to address CR419242 Completed on 7/21/11 11-236 4/25/11 I existing loading configurations LA2520 & 2521 (LTR 11-262)

Fitness for Duty Exemption - build into program 1.. Preplan ned and consistent work shift start times and Complete 10-4488 5/26/11 hours. LA2398 I HAP-Nuclear p18 rev, 12

2. Require 10 hours0.417 days <br />0.0595 weeks <br />0.0137 months <br /> of restorative rest when crews are off

shift. I Earthquake restoration plans- see attached enclosures 8 and Enclosure 8 - Complete  !

9 prior to restart See Enclosures 11-520* 9/17/11 Enclosure 9- Long Term 8 & 9 (attached)

Actions Completed as part 1

of CAL Submit evaluation of seismic event to LBB analysis of record Complete 11-q66E 10/31/11 LA 2901 by 3/21/13.13-143 Seismic ev13nt action plan - .__.. -

Complete

1. Install upgraded MCR seismic instrumentation and power LA2898, 2899 &

11-5208 10/31/11 13-143 2 .. Reevaluate SSC from IPEEE with HCLPF < 0.3g 2900

3. Develop Rx Vessel Internal inspection plant{with vendor)

Seismic long term actions-

1. Sample analysis of ASME Class 1, 2, & 3 piping systems lAW EPRI-6695.

2. Evaluate Aux Building for seismic effect Complete 11-577A 10/18/11 LA2893 & 2897

3. Incorporate results of RG 1.166/67 evaluation into 13-143 UFSAR Seismic long term actions- LA2895, 2896, Complete 11-5778 10/28/11

1. UQQ_ate ground response motion effects 2907 & 2876 13-143 Attachment

CAlLA Ltr No. Date Commitment

• Status/Comments Number

2. : Establish seismic margin management program (SMMP) UFSAR Sections- 2.7,

3. UFSAR updates- event, RG 1.167, SMMP, Incorporate 3.7.7, and 3.7.4 UFSAR Sections RG 1.166 and 1.167 11-5200 Long Term commitment list Appendix 9 from 11-520 (became LC854 and 11/7/11 CAL- 10 items) associated LAs Seismic- Complete 11-577C 11/4/11 1. Implement SMMP LA2890-& 2891 UFSAR 3.7.7

2.

• Notify NRC when discontinue using the SMMP Still in use PAry1S- Replace indicator for 2-CC-TV-204C during next Closed CR457575 12-005 1/11/12 outage of sufficient duration. CA222901 and U2 Ops Log entry on 10/9/12 @ 0804 PAMS- Replace indicator for2-CC-TV-202A during next Closed 12-231 4/3/12 outage of sufficient duration. CR464068 CA227860 and U2 Ops Log entry on 10/9/12 @ 0520 BOB Emergency Preparedness requirements LC795 and 12-207B 5/9/12 Closed associated LAs Periodically verify the design bases capability of JOG Class 0 6/18/12 LA1073 Closed MOVs by 9/25/12.

PAry1S- Replace indicator for 1-CC-TV-1 02E during next Complete. WO CR481696 12-542 8/22/12 outage of sufficient duration 59102493464- cancelled.

Completed tool pouch Upgrade commitment to ANSI/ANI 3.5-2009 for simulator 12-609 9/27/12 LA4032 Complete traiilinQ PAMS- Replace indicator for 1-CC-TV-104B during.next Complete. WO outage of sufficient duration. 59102519969 - cancelled.

Completed tool pouch. U1 CR489985.&

12-692 11/14/12 Ops Log entry on 5/30/13 493908

@ 0816 BOB Seismic Walkdowns -Inaccessible walkdowns will be Complete. MWO 12-207H 11/27/12 completed in the Spring or Fall of 2013. LA4216 & 4217 59102498388 & MWO I 59102547644 12-207G 11/27/12 Seal cover for Turbine Building manhole 1-EP-MH-16 and LA4207 -

Complete_._

CAlLA Ltr No. Date Commitment Status/Comments Number op~n conduit within mp.nhole by 12/31/13. W0591 02604341 &

DC-NA-13-00039 PAMS- Replace indicator for 2-CC-TV-202A during next ~-~

Complete. WO outage of sufficient duration 59102530095 - cancelled.12-693 12/7/12 CR493382 . Completed tool pouch. U2

~

Ops Log entry dated 4/8/13

@ 0956 Submit exam results for U2 SG hot/cold leg nozzle to safe end 13-189 4/4/13 LA4614 Complete weld performed during the spring 2013 RFO RR N2-14-LMT-001 Perform examination of SG hot/cold leg ~

Open 13-189A 4/13/13 no:z;zle to safe end welds during the U2 fall R*Fo LA4629

1) 60 days after PWROG establishes new acceptance criteria LA4779, 4780,

-:develop plan for compliance and communicate to NRC.13-234 05/15/13 4781' 4782 & Open

2) Remove fiber and install RMI in 2016 RFO for both units.

4786

3) Update the UFSAR.

PAMS- Replace indicator for 2-CC-TV-204A/B during plant Complete. WO condition of sufficient duration to permit repair. CR521389 59102628249 13-499 8/30/13 CR521390 wo 591 02628290 -

CR523705 cancelled. U2 Ops Log

'* CR523707 entry dated 2/2/12@ 1521 i and 1550.

PAMS- Replace indicator for 2-CC-TV-202A during plant Complete. WO condition of sufficient duration to permit repair. CR534036 59102680516- cancelled.14-005 1/10/14 CR535963 U2 Ops Log entry dated 2/2/12@ 1521 and 1550.

PAMS- Replace indicator for 2-CC-TV-202F during plant Complete. WO condition of sufficient duration to permit repair. CR535698 59102685457 cancelled.14-033 1/30/14 CR537506 U2 Ops Log entry dated I

2/2/12@ 1521 and 1550.

Schedule for Response to Request for Information Regarding 14-273 6/16/14 Flooding Hazard Reevaluation Report. Provide final response LA5477 Open to RAI 3.4-1 by November 15, 2014. - -~

Enclosure 8 to 11-520 .

- 4 _*

I NEAR-TERM ACTIONS TO BE COMPLETED PRIOR TO UNIT RESTART Restart Activity Comments Status/Comments A. Seismic Monitoring and Design Basis 1 Provide temporary backup power to the Main Control Room Complete. See Attachment Seismic Monitoring Panel. 4 of NRC Restart Complete Readiness Inspection Report dated November 30, I

2011 2 Install temporary free field seismic monitoring instrumentation. Prior to Unit 1/2 Restart Same as above 3 Revise Abnormal Procedure 0-AP-36 to improve procedural Same as above guidance for determining whether an onsite earthquake Prior to Unit 1/2 Restart exceeds OBE and/or DBE peak acceleration criteria.

B. Nuclear Fuel

1. Unit 1 Core I

Prior to Unit 1 entering Complete. LA2779 a Perform hot rod droP,.testing.

Mode2

2. Unit 2 Core a Perform RCCA drag testing. Prior to Unit 2 onload Complete. LA2780 Prior to Unit 2 entering

• Complete. LA2781 b Perform hot rod drop testing. Mode2 --*

c Perform routine binocular visual inspection during core Complete. Refer to NRC

. I.

offload. I Prior to Unit 1 Restart Technical Audit Report dated October 25, 2011 d Perform video inspections on 13 benchmark assemblies and Same as above I Prior to Unit 1 Restart additional vendor-recommended assemblies.

e Perform video inspection of RCCA hubs. Prior to Unit 1 Restart Same as above Perform video inspections on assemblies with anomalies Same as above f Prior to Unit 1 Restart observed during binocular inspections.

C. Root Cause Evaluations I

I 1 Reactor Trip I Prior to Unit Y2 Restart Complete. See RCE1 061 2 Unit 2H Emergency Diesel Generator Coolant Leak Prior to Unit 1/2 Restart Complete. See BCE 1062

NEAR~ TERM ACTIONS TO BE COMPLETED PRIOR TO UNIT RESTART Restart Activity Comments Status/Comments and LA2782 D. Inspections 1 Steam Generators - Perform a 20% sample inspection of Unit Complete. LA2783 Prior to Unit 1/2 Restart 1 and Unit 2 steam generators.

2 Containment- Perform containment inspections to identify and Complete. LA2816, 2817 &

remove debris that may have resulted from the earthquake, as Prior to Unit 1/2 Restart 0-GOP-30 log required.

3 Containment Sum12 Strainers Complete. LA2784 Perform a visual examination of the sump strainer gaps in Prior to Unit 1/2 Restart accordance with the applicable _Qeriodic test.

4 lnservice lnsQection; Complete. LA2820 Prior to Unit 1/2 Restart Perform sample weld inspections.

5 Buried PiQe Monitoring/Ground Water Monitoring Program Complete. LA2820 and Perform buried pipe' inspections of: ER-AA-BPM-1 01

• the two areas of buried fire protection pipe that are currently ;excavated,

• the Unit 2 circulating water discharge tunnel and Prior to Unit 1/2 Restart associated liquid waste line, and

• the buried pipe between the Unit 1 auxiliary feedwater tunnel and the Unit 1 Quench Spray Pump House.

E. Testing 1 Complete Unit 1/2 Surveillance Periodic Tests as determined Prior to and during Unit 1/2 Complete. LA2785 and by the Seismic Event Response Team. Startup per Technical 2796 Specifications (Unit specific tests will be completed prior to and during that Unit's startup)

Enclosure 9 from 11-520 LONG-TERM ACTIONS TO BE COMPLETED AFTER UNIT RESTART I Activity LA Number A. Seismic Monitoring,and Evaluations I

1 Provide permanent backup power to the Main Control Room Complete. 2743 Seismic Monitoring Panel.

2 Install permanent free field seismic monitoring instrumentation. Complete. 2744 3 Reevaluate plant equipment identified in the IPEEE review with Complete. 2899 HCLPF capacity <0.3g.

4 Perform seismic evaluations in the context of EPRI NP-6695, NRC Complete. 2893 &

Gl-199 and as an ou~come of NRC Task Force recommendations 2894 identified in SECY -1 ~ -0124.  !

B. Reactor Vessel Internals 1 Develop a plan with the NSSS vendor consisting of additional Complete. 27 46 &

evaluations or inspections, as warranted, to assure long term 2900 reliability of the reactor internals.

I Attachment to 11-5200 Long-Term Actions Commitment List North Anna Power Station Units 1 and 2 Item I Scheduled LA Number Commitment No. Completion Date Dominion will per(brm long-term evaluations of plant structures, Complete. 2893 &

systems and components I

in accordance with RG 1.167/EPRI NP-6695, ~

2894 1 Section 6.3. Any anomalies identified during the evaluations will be April 30, 2013 entered into the corrective action system and evaluated for extent of condition.

Dominion will develop a plan to characterize the seismic source and Complete. 2895 2 any special ground motion effects due to the relative locations of the *March 31 , 2Ul2 fault and the site and will update the NRC accordingly.

Dominion will revise the North Anna Updated Final Safety Analysis Report to document:

a. The recorded August 23, 2011 seismic event. April 30, 2012 Complete. 2896

b. A summary of the evaluation and results of the seismic analysis Complete. 2907 April 30, 2013 of the recorded ev~nt completed per RG 1.167/EPRI NP-6695.

3 c. Design controls on seismic margin management (i.e., the Complete April 30, 2012 Seismic Margin Management Plan). 2896

. d. Incorporation of Regulatory Guide (RG) 1.166, "Pre-Earthquake Complete. 2897 Planning and Immediate Nuclear Power Plant Operator.

December 31 ,

Post-Earthquake Actions," and RG 1.167, "Restart of a Nuclear 2012 Power Plant Shut Down by a Seismic Event," into the North ~

Anna licensing basis.

Dominion will imp~ement a design change to replace the existing December 31, Complete. 2898 seismic equipment and Main Control Room indication with upgraded 2012 (subject to and enhanced seismic monitoring instrumentation equipment, which receipt of seismic 4

includes installatiqn of a permanent, free field seismic monitor. monitoring Permanent, seis~ically qualified backup power to a new Seismic _ equipment-and MonitorinQ Panel will also be installed including a backup battery power outaQe

Long-Term Actions Commitment List North Anna Power Station Units 1 and 2 Item Scheduled LA Number Commitment No. I Completion Date supply. The seismic instrumentation will be installed and maintained in schedules) accordance with RG 1.12, Rev 2, Nuclear Power Plant Instrumentation for Earthquakes. The project will also install seismic recording instrumentation at the station Independent Spent Fuel Storage Installation (ISFSI) pad.

Dominion will perform a re-evaluation of the plant equipment identified Complete. 2899 5 in the IPEEE review with HCLPF capacity <0.3g, which will include an March 31, 2013 assessment of potential improvements.

Dominion will develop a plan with the NSSS vendor consisting of Complete. 2900

• 6 additional evaluations or inspections, as warranted, to assure long term February 29, 2012 reliability of the reactor internals.

Dominion will perform a comparison of the calculated load from the Complete. 2901 7 August 23, 2011 earthquake and the existing leak-before-break (LBB) March 31, 2013 analysis and submit the results.

2902- Plan In accordance submitted for with the MRP-227 review. 2903 is Dominion will perform inspections at North Anna Power Station in inspection plan, tracking 8 which will be performance of accordance with the latest MRP-227 revision approved by the NRC.

provided by inspections to be March 31, 2013 completed by end of 2020.

Dominion will re-e,valuate the Time-Limiting Aging Analyses (TLAAs) Complete. 2904 that include seismic inputs to either: 1) quantitatively demonstrate that 9 March 31, _?011 the TLAAs are still bounding, or 2) re-analyze the TLAAs, based on the August 23, 2011 earthquake.

Dominion will implement a long term Seismic Margin Management Plan December 31, Complete. 2905 10 to address the impact of the August 23, 2011 earthquake. Specifically, 2011 to ensure adequate seismic marqins are maintained for plant SSCs,

Long-Term Actions Commitment List

• North Anna Power Station Units 1 and 2 Item Scheduled LA Number Commitment No. Completion Date Dominion will revi~e the design change process for North Anna Power Station to require 'explicit evaluation of plant modifications for the effects of the Augl!.lst 23, 2011 earthquake using In-Structure Response ---

Spectra (ISRS) for the event for the Containment, Auxiliary Building, and other buildings containing safety related SSCs developed based on actual time-histories recorded during the event. In support of future plant design changes, the evaluation of plant SSCs will require design verification and code compliance with the stresses, loads, accelerations, and displacements generated from the analysis with the design basis ISRS and the analysis with the ISRS for the August 23, 2011 earthquake, 'whichever are higher.

Dominion will provide 30-days prior written notification to the NRC if it Complete. 2906

• determines the Seismic Margin Management Plan is no longer required based on the implementation of comparable actions as part of the N/A resolution of the NRC's recommendations emanating from the Fukushima Daiichi Task Force and/or Generic Issue (GI)-199.

ML14226A395 OFFICE NRR/DORULPL4-1 /PM NRR/DORL!LPL2-1/LA N RR/DORULPL2-1 /BC NRR/DORLILPL2-1 /PM NAME VSreenivas SFigueroa A Pascarelli VSreenivas DATE 08/14/14 08/14/14 08/22/14 08/22/14