ML14338A809

From kanterella
Jump to navigation Jump to search
Audit of Regulatory Commitment Management
ML14338A809
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 12/15/2014
From: Geoffrey Miller
Plant Licensing Branch II
To: Capps S
Duke Energy Carolinas
Miller G
References
Download: ML14338A809 (7)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Steven D. Capps Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078-8985 December 15, 2014

SUBJECT:

MCGUIRE NUCLEAR STATION, UNITS 1 AND 2-AUDIT OF REGULATORY COMMITMENT MANAGEMENT

Dear Mr. Capps:

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute 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 the regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when approprjate, reported to the NRC.

An audit of McGuire Nuclear Station, Units 1 and 2 (McGuire) commitment management*

program was performed during November and December, 2014. The NRC staff concludes, based on the audit, that McGuire has implemented an acceptable program for implementing and managing NRC commitments. Details of the audit are set forth in the enclosed audit report.

If you have any questions, please call me at 301-415-2481.

Docket Nos. 50-369 and 50-370

Enclosure:

As stated cc w/encl: Distribution via Listserv G. Edward Miller, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370

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

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 regulatory commitments are being effectively implemented. An audit of the McGuire Nuclear Station, Unit 1 and 2 (McGuire) commitment management program was performed at NRC Headquarters during the period of November to December 2014. The audit reviewed commitments made since the previous audit on November 11, 2011, 2011 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML11297A090).

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 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 licen-see's commitment management system includes a mechanism to ensure traceability of comm.itments 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 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 (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 table contains a list of those documents that were selected for additional review during this audit.

The NRC staff reviewed the report generated by the licensee's tracking program and associated documentation of the selected representative sample items. Additionally, the NRC staff's review of the commitment list found that the licensee's commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant procedures that had been revised or implemented as a result of commitments made by the licensee to the NRC. The NRC staff also

(

reviewed items originally added to the commitment tracking system, but were later modified. In these cases, the NRC staff verified that the licensee correctly applied the NEI-99-04 definition in determining that they were not commitments.

The NRC staff noted that, where appropriate, procedures have annotations to refer to commitments. These annotations serve to prevent future procedure changes from inadvertently deleting or altering an item without having gone through the commitment change process.

Additionally, the annotations specifically refer to its related commitment allowing for enhanced traceability.

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 McGuire is contained in Licensee Procedure Nuclear System Directive 214, Revision 12, "Regulatory Commitment Management Program."

2.2.1 Audit Results Table 1 contains a list of those documents that were selected for additional review during this audit...

The NRC staff found that the licensee's commitment tracking program had captured all the regulatory commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant procedures, assessment recommendations, corrective actions, and action requests that had been initiated or revised as a result of commitments made by the licensee to the NRC. Additionally, the licensee's procedure for managing regulatory commitments appears to be functionally equivalent to NEI 99-04.

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 audit did not reveal any misapplied commitments.

The NRC staff did note one LAR that included a commitment to implement compensatory measures where, during the NRC staff review, it was identified that the compensatory measures were a necessary component of the safety finding. In this instance, the implementation of the compensatory measures was elevated to an obligation via language in the implementation statement. Therefore, the commitment was not 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, exemptions and relief request safety evaluations 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.

A review of all the licensing actions since November 2011 did not reveal any misapplied commitments.

3.0 CONCLUSION

The NRC staff concludes that, based on the above audit: (1) the licensee had implemented or is tracking for future implementation regulatory commitments; and (2) the licensee had implemented an acceptable program to manage regulatory commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT George Murphy Kay Crane Principal Contributor: G. Edward Miller Date: December 15, 2014

Attachment:

Summary of Commitments Reviewed

T bl 1 D a e -

ocuments R ev1ewed d.

d' unng au 1t Item# Source Commitment Timeframe Comments 1

RAI Response McGuire commjts to implement the Dec 31,2013

  • G-12-0371 (ML12250A622}

guidelines of Section 7.3 of MRP CA#6 227-A, including the performance of inspections within the time frame specified in Tables 4-3, 4-6, 4-9, and 5-3 of MRP 227-A 2

RAI Response After the [Leading Edge Flow Meter Seven months M-12-4729 (ML12199A023}

(LEFM)] Checkplus system is after the LEFM CA# 1 installed and operational on the system is CA#5 respective Unit, six months of data installed and will be collected comparing the LEFM operational on Checkplus operating data to the the respective Venturi data to verify consistency Unit between thermal power calculation based on LEFM and other plant parameters 3

RAI Response

[McGuire Nuclear Station] will July 6, 2012 M-12-4728 (ML12160A085) complete the evaluation of the CA#1

[Measurement Uncertainty Recapture (MUR)] power uprate against the

[Environmental Qualification]

Program requirements and provide the results of this evaluation 4

LAR Duke Energy will re-evaluate the Prior to M-12-9220 (ML12082A210)

Loss-of-Coolant-Accidents (UFSAR implementation CA#18 15,6.5) consistent with the reload of the MUR methodolo_gy power uprate 5

LAR Duke Energy will submit a follow-up One year M-14-7825 (ML13262A500) administrative LAR to delete the following the M-14-11256 superseded TS requirements implementation IP-A-3002-009 of the OP-1-A-61 00-01 OF modification for the final Unit 6

NRC Duke energy will implement During M-14-00562 Amendment compensatory measures during each performance of UFSAR change (ML14231A634) respective vital battery replacement the request Package replacements 14-28 7

Relief Request Another weld in the RI-ISI program During the next M-12-09687 (Ml 12359A061) with the same risk-significance and scheduled subject to the same degradation Unit 2 refueling mechanism as the weld in this relief outage request will be examined 8

Duke N/A N/A NSD-214, Rev 12 Commitment Management Procedure

  • This action was initially proposed as a commitment by the licensee. During the NRC staff review, it was identified that the compensatory measures were a necessary component of the safety finding. Therefore, the implementation of the compensatory measures was elevated to an obligation via language in the implementation statement.

ML14338A809 Sincerely, IRA/

G. Edward Miller,. Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsNrrDorllpl2-1 Resource RidsNrrPMMcGuire Resource OFFICE NRR/LPL2-1 /PM NRR/LPL2-1/LA NRR/LPL2-1 /BC NAME GEMiller SFigueroa RPascarelli DATE 12/11/14 12/11/14 12/15/14

Retrieved from "https://kanterella.com/w/index.php?title=ML14338A809&oldid=5199472"