ML15043A716
| ML15043A716 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/19/2015 |
| From: | Thadani M Plant Licensing Branch 1 |
| To: | Joseph Pacher Exelon Generation Co |
| Thadani M | |
| References | |
| TAC MF5095 | |
| Download: ML15043A716 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 19, 2015 Mr. Joseph E. Pacher Vice President RE. Ginna Nuclear Power Plant Exelon Generation Company, LLC 1503 Lake Road Ontario, NY 14519
SUBJECT:
RE. GINNA NUCLEAR POWER PLANT - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS, REGULATORY COMMITMENTS CHANGES, AND APPROPRIATE APPLICATION OF REGULATORY COMMITMENTS. (TAC NO. MF5095).
Dear Mr. Pacher:
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the Nuclear Regulatory Commission (NRC) informed the 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 the 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 those regulatorf commitments are being effectively implemented.
On December 4 and 5, 2014, the NRC staff performed an audit of the licensee's commitment management program at RE. Ginna Nuclear Power Plant (Ginna). The NRC staff selected a sample of the licensee's records of regulatory commitments and regulatory commitment changes. The selected sample was used to review the licensee's management of the regulatory commitments, regulatory commitment changes, and verification that the regulatory commitments are being appropriately applied to ensure that they did not constitute obligations under the NRC's regulatory requirements.
Based on the audit of a selected sample of the regulatory commitments, the NRC staff concludes that the licensee has implemented its regulatory commitments management program and regulatory commitments change program in accordance with the industry guidance in NEI 99-04. The NRC staff's review of the sample confirmed that the licensee is applying the regulatory commitments in an appropriate manner to ensure that the regulatory commitments did not involve any obligations under the NRC's regulatory framework. The details of the audit, including the NRC staff observations and recommendations, are set forth in the enclosed audit report.
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS PROGRAM R.E. GINNA NUCLEAR POWER PLANT. LLC R.E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244
1.0 INTRODUCTION
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the Nuclear Regulatory Commission (NRC) informed the 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 the 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.
NEl-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 On December 4 and 5, 2014, the NRC staff performed its triennial audit of the regulatory commitment management program; regulatory commitments change program, and verification that the regulatory commitments are being appropriately applied at R.E. Ginna Nuclear Power Plant (Ginna). The audit consisted of (1) verification of the licensee's documentation and implementation records to ensure that the regulatory commitments are being implemented consistent with the program and in accordance with the industry guidance contained in NEI 99-04, (2) verification of the licensee's documentation and implementation of regulatory commitment changes to ensure that the regulatory commitment changes are consistent with the guidance contained in NEI 99-04, and (3) verification that all the regulatory commitments reviewed were being correctly applied to ensure that they did not constitute regulatory obligations under the NRC's regulatory requirements framework.
Enclosure
2.1 Verification of Licensee's Implementation of Regulatory Commitments Ginna is a part of Constellation Energy Nuclear Group's (CENG's) fleet that was acquired by Exelon. As a result of the consolidation of the CENG's fleet into the Exelon's corporate structure, the Ginna's commitment management activities were folded into the Exelon's templet of the management of regulatory commitments.
The NRC staff's primary focus of this part of the audit was to confirm that the licensee has implemented the regulatory commitments made to the NRC as part of past licensing processes.
For commitments that had not yet been implemented, the NRC staff ascertained that they have been captured in the management program for appropriate implementation. The audit also verified that the licensee's commitment management system includes a mechanism to ensure tracking of the regulatory commitments.
2.1.1 Audit Scope The NRC staff focused the audit on a sample of regulatory commitments. The sample was selected from information obtained from the licensee prior to the audit visit and consisted of regulatory commitments made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests etc.) or licensing activities (bulletins, generic letters, etc.). The sample was representative of the licensee's regulatory commitments database.
The audit excluded the following types of commitments that were part of licensee's internal 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).
(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.
The attached Table 1 summarizes the details of the audit results. Table 1 displays the regulatory commitment source document in column 1, regulatory commitments description and status and actions are in summarized in column 2, and if any changes were made to regulatory commitments, they are descried in Column 3. If no changes are made, the commitments change column is left blank. The commitment closure status is indicated in the commitment description in column 2. The licensee provided the accession numbers for all the documents related to actions taken including changes made to the regulatory commitments.
Table 1- Regulatory Commitments Record Sample Audited Source Commitment Changes Document Cyber Security Complete Task 8 in the implementation schedule Changed implementation date Amendment (ML110980538) commitment by letter dated (113) 08/29/2014(ML14241A526)
Fukushima/ Complete the implementation schedule in FLEX Attachment 1 of Letter from John Spina to NRC Dated 05/11 /2012 (ML12136A231)
Fukushima/ Perform Flood hazards reevaluation by FLEX 03/12/2015, and other actions, in letter from Sam Belcher to NRC dated 06/08/2012 ML12164A369)
Fukushima/ Submit intention to follow guidance or propose FLEX alternative approach within 60 days of issuance of NRC guidance, in letter from Sam Belcher to NRC dated 06/08/2012 (ML12164A369)
Fukushima/ Improvements related to FLEX will be FLEX implemented prior to RFO startup in Fall 2015, per letter from Mary Korsnick to NRC dated 10/26/2012 Fukushima/ Submit seismic walkdown results by 07/31/2013 By letter from Mary G Korsnick to FLEX and submit seismic walkdown results for internal NRC dated 07/25/2013, move inspections of MCC C and Bus 14 by 01/31/2016, date to18 months sooner (by per letter from John Spina to NRC dated 07/31/2014) (ML13210A034) 12/21/2012(ML12362A452, ML12362A448, ML12362A451)
Fukushima/ Include the status of the implementing actions FLEX identified in Section 4.12 of the Communications Assessment as part of the six-month status reports prepared pursuant to Section IV.C.2 of NRC Order EA-12-049 in six-month intervals from 02/28/2013 by letter from Mary G Korsnick to NRC dated 02/28/2013. (ML13066A171)
Fukushima/ Ensure the final design details and associated FLEX procedure guidance for the SFP Integrated Plan, as well as any revisions to the information contained in the attachments, is provided in the 6-month Integrated Plan updates required by NRC Order Number EA-12-051. by letter from Mary G Korsnick to NRC dated 02/28/2013.
Source Changes Commitment Document Fukushima/ Submit the base case velocity profile and FLEX supporting subsurface materials and properties (Electric Power Research Institute (EPRI)
Technical Report 1025287, Section 4, "Seismic Hazard and Screening Report," 2nd Bullet, "Seismic Hazard Results: GMRS," Items 3.a and 3.b) by September 12, 2013 for Ginna. by letter from Mary G Korsnick to NRC dated 04/26/2013, (ML13120A105)
Fukushima/ Submit the remaining EPRI Technical Report Changed due date to 03/31/2014 FLEX 10/252/87, Section 4, "Seismic Hazard and by letter from John Spina to NRC Screening Report," information seven months dated 09/12/2013 following the NRC endorsement of the revised (ML13259A044)
EPRI ground motion attenuation model for the CEUS, or the NRC determines that the industry is unable to address its concerns with the EPRI updated ground motion model for CEUS licensees by letter from Mary G Korsnick to NRC dated 04/26/2013. (ML13120A105)
Fukushima/ Submit a schedule for implementing the ESEP FLEX activities and the Seismic Risk Assessment for Ginna within 60 days following the NRC's endorsement, acceptance, or rejection of the Augmented Approach guidance. By letter from Mary G Korsnick to NRC dated 04/26/2013.
Fukushima/ Ginna will implement multi-soLJrce dose FLEX assessment capability by 12/31/2014 by letter from Mary G Korsnick to NRC dated 06/21/2013.
CENG will submit the Ginna Expedited Seismic Fukushima/ Evaluation Process (ESEP) report by 12/31/2014 FLEX by letter from Mary G Korsnick to NRC dated 06/28/2013. (ML13190A471)
Fukushima/ If Ginna does not screen out based on the Ginna screens out of the ESEP FLEX Augmented Approach screening criteria, Ginna and does not need to prepare will complete the ESEP Modifications not reports summarizing the ESEP requiring outages two years after the ESEP report evaluations and results. Per the submittal by 12/31/2016 by letter from Mary G screening process, an ESEP Korsnick to NRC dated 06/28/2013. Report will not be submitted for (ML13190A471) Ginna. Since Ginna screens out based on the ESEP screening criteria, no ESEP modifications will be completed for Ginna. By letter from Mary G Korsnick to NRC dated 03/31/2014.
Source Changes Commitment Document Fukushima/ If Ginna does not screen out based on the Ginna screens out of the ESEP FLEX Augmented Approach screening criteria, Ginna and does not need to prepare will complete the ESEP Modifications within two reports summarizing the ESEP outages after December 2014 by 04/30/2017. evaluations and results. Per the Letter from Mary G Korsnick to NRC dated screening process, an ESEP 06/28/2013. (ML13190A471) Report will not be submitted for Ginna. Since Ginna screens out based on the ESEP screening criteria, no ESEP modifications will be completed for Ginna. By letter from Mary G Korsnick to NRC dated 03/31/2014.
Fukushima/ If Ginna does not screen out based on the SPID Ginna screens out of the ESEP FLEX screening criteria, Ginna will complete the and does not need to prepare Seismic Risk Evaluation (with a SFP Evaluation reports summarizing the ESEP and High Frequency Confirmation) by 06/30/2017 evaluations and results. Per the by letter from Mary G Korsnick to NRC dated screening process, an ESEP 06/28/2013. (ML13190A471) Report will not be submitted for Ginna. Since Ginna screens out based on the ESEP screening criteria, no ESEP modifications will be completed for Ginna. By letter from Mary G Korsnick to NRC dated 03/31/2014.
Fukushima/ Provide specific requirements of the procedure FLEX controlling irradiated equipment or materials stored in the Spent Fuel Pool (SFP), including details of the analysis to be performed, to the NRC in the August 28, 2015 Ginna Overall Integrated Plan (OIP) status update, due 08/28/2015 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Fukushima/ The full hydrodynamic/seismic qualification details FLEX will be forwarded to the NRC on February 28, 2014 with the second Ginna OIP status update, due 02/28/2014 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Fukushima/ The final mounting details for the horn antenna, FLEX waveguide assembly, waveguide piping, and radar sensor will be available upon completion of the final design and will be forwarded to the NRC on February 28, 2014 with the second Ginna OIP status update, due 02/28/2014 by letter from Mary G Korsnick to NRC dated 09/23/2013.
Source Changes Commitment Document Further details of the qualification and test program used to confirm the reliability of the Fukushima/FLE permanently installed equipment during and x following Beyond Design Bases Events, including seismic conditions, will be forwarded to the NRC on 02/2/2014 with the second Ginna OIP status update, due 02/28/2014 by letter from Mary G Korsnick to NRC dated 09/23/2013.
Further details on independence and channel Fukushima/FLE separation of the permanently installed x equipment will be provided in the August 28, 2015 Ginna OIP status update, due 08/28/2015 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Further details on the AC and DC power supplies Fukushima/FLE of the permanently installed equipment will be x forwarded to the NRC on 02/28/2014 with the second Ginna OIP status update, due 02/28/2014. Letter from Mary G Korsnick to NRC dated 09/23/2013.
Fukushima/ The final calibration methodology will be FLEX forwarded to the NRC on 08/2/2014 with the third Ginna OIP status update, due 08/28/2014 Letter from Mary G Korsnick to NRC dated 09/23/2013, (ML13269A011)
Fukushima/ Specific details of the functional and calibration FLEX test program, including frequencies, will be developed as part of the final instrument design and will be forwarded to the NRC on 08/28/2014 with the third Ginna OIP status update, due 08/28/2014 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Fukushima/ The primary and alternate access route FLEX evaluation, continuous habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for verbal communications with decision makers for the various SFP drain down scenarios and external events will be evaluated as part of the response to Order EA-12-049. This information will be provided in the August 28, 2015 Ginna OIP status update, due 08/28/2015 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Source Commitment Changes Document Fukushima/ The reasons justifying why the display locations FLEX selected enable the information from these instruments to be considered "promptly accessible" from a response time perspective, including a discussion of various drain-down scenarios, will be provided in the August 28, 2015 Ginna OIP status update, due 08/28/2015 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Fukushima/ The list of procedures for operating (both normal FLEX and abnormal response), calibration/test, maintenance and inspection, along with the technical objectives to be achieved within each procedure will be provided in the August 28, 2015 Ginna OIP status update, due 08/28/2015 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Fukushima/ The preventive maintenance, test and calibration FLEX program will be available following completion of the final design and will be summarized in the 08/28/2014 Ginna OIP status update, due 08/28/2014 by letter from Mary G Korsnick to NRC dated 09/23/2013. (ML13269A011)
Fukushima/ The compensatory actions to take when both FLEX channels are out of service, and the applicable administrative requirements and implementation procedures will be available and the information summarized in the August 28, 2015 Ginna OIP status update, due 08/28/2015 by letter from Mary G Korsnick to NRC dated 09/23/2013.
Fukushima/ The compensatory actions to take when a FLEX channel is not restored within 90 days, and the applicable administrative requirements and implementation procedures will be available and the information summarized in the Ginna OIP status update, due 08/28/2015 by letter from Mary G Korsnick to NRC dated 09/23/2013.
Source Commitment Changes Document Fukushima/ Ginna will provide the information requested by FLEX the NRC's Requests for Additional Information contained in the Interim Staff Evaluation regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, due 09/30/2014 by letter from Mary G Korsnick to NRC dated 02/24/2014. (ML14069A180)
Fukushima/ Ginna will perform a High Frequency Confirmation FLEX due in accordance with the NRC prioritization process by letter from Mary G Korsnick to NRC dated 03/31/2014. (ML14099A196)
Fukushima/ Ginna will revise the Mitigating Strategies Overall FLEX Integrated Plan (OIP) to reflect the FLEX equipment storage design criteria regarding the protection of FLEX equipment for high wind hazards in accordance with Section 7.3.1.1 of NEI 12-06, and will design tornado protection based on these design criteria. This change will be incorporated in the next 6-month update report, due 08/28/2014, by letter from Mary G Korsnick to NRC dated 05/16/2014. (ML14176A129) 2.1.2 Audit Results The NRC staff found that the Exelon's administrative procedure LS-AA-110, Revision 10, "Commitment Management," and Exelon's procedure, "Commitments Tracking Program For Use with Passport," generally implement the industry guidance for management of regulatory commitments and management of regulatory commitment changes contained in the NEl-99-04 guidelines. The documentation provided by the licensee during the audit confirmed the NRC staff's conclusion that the licensee's regulatory commitments are being tracked effectively.
2.2 Verification of the Licensee's Regulatory Commitment Change Management The NRC staff's primary focus of this part of the audit was to confirm that the licensee has implemented regulatory commitment changes consistent with the industry guidance contained in NEI 99-04. Table 2, "Regulatory Commitments Changes," summarizes the licensee's records of the changes made to the regulatory commitments as part of licensing processes. The commitment changes are described by identifying the source of the commitment, description of the commitments, and the change(s) made to the commitments. The changes are reported to the NRC as provided in the industry guidance in NEI 99-04. The NRC staff's audit of the commitment change program verified that the licensee was following the industry guidance and informing the NRC of the changes made. The audit also verified that the licensee's commitment management system includes a mechanism to ensure tracking of the regulatory commitment changes.
Table 2-Regulatory Commitments Change Records Source Changes Commitment Document License Renewal Perform 2 structural integrity tests at design Perform 2 structural integrity tests pressure during period of extended during period of extended operation. (ML041400502) operations at a pressure that is consistent with the ILRT Type A methodology set forth in R.G.
1.163 (ML11119A230)
Cyber Security Complete Task 8 in the implementation Changed implementation date (113) schedule (ML110980538) commitment by letter dated August 29, 2014 (ML14241A526)
Commitment Perform inspections of thimble tubes for Change from RFOs beginning in Change 2012-001 wear and stress corrosion cracking 2005 and 2009 to RFOs beginning in 2015(ML13070A051)
Fukushima/FLEX Submit seismic walkdown results by By letter from Mary G Korsnick to 07/31/2013 and submit seismic walkdown NRC dated 07/25/2013, move date results for internal inspections of MCC C and to 18 months sooner (by Bus 14 by 01/31/2016, per letter from John 07/31/2014)
Spina to NRC dated 12/21/2012 (ML12362A452, ML12362A448, ML12362A451)
Fukushima/FLEX Submit the remaining EPRI Technical Report Changed due date to 03/31/2014 1025287, Section 4, "Seismic Hazard and by letter from John Spina to NRC Screening Report," information seven dated 09/12/2013(ML13259A044) months following the NRC endorsement of the revised EPRI ground motion attenuation model for the CEUS, or the NRC determines that the industry is unable to address its concerns with the EPRI updated ground motion model for CEUS licensees by letter from Mary G Korsnick to NRC dated 04/26/2013. (ML13120A105)
Fukushima/FLEX If Ginna does not screen out based on the Ginna screens out of the ESEP Augmented Approach screening criteria, and does not need to prepare Ginna will complete the ESEP Modifications reports summarizing the ESEP not requiring outages two years after the evaluations and results. Per the ESEP report submittal by 12/31/2016 by screening process, an ESEP letter from Mary G Korsnick to NRC dated Report will not be submitted for 06/28/2013. (ML13190A471) Ginna. Since Ginna screens out based on the ESEP screening criteria, no ESEP modifications will be completed for Ginna. By letter from Mary G Korsnick to NRC dated 03/31/2014. (ML14099A196)
2.2.1 Audit Results The NRC staff found that the Exelon's administrative procedure LS-AA-110, Revision 10, "Commitment Management," and Exelon's procedure, "Commitments Tracking Program For Use with Passport," generally implement the industry guidance for management of regulatory commitments and management of regulatory commitment changes contained in the NEl-99-04 guidelines. The documentation provided by the licensee during the audit confirmed the NRC staff's conclusion that the licensee's regulatory commitments are being tracked effectively.
2.3 Verification of Appropriate Application of Regulatory Commitments.
The NRC staff reviewed the licensee's regulatory commitments in Table 1 to determine if any of the audited regulatory commitments constituted obligations under the NRC's regulatory requirements. Based on this review, the staff concludes that the licensee is applying the regulatory commitments in an appropriate manner.
3.0 CONCLUSION
Based on the above, the NRC staff concludes that: (1) Ginna is implementing and tracking the regulatory commitments and changes to the regulatory commitments consistent with the NRC accepted industry guidance contained in NEI 99-04, (2) Ginna has implemented an effective programs to manage regulatory commitment changes, and (3) there were no misapplied regulatory commitments in the sample audited by the NRC staff.
4.0 LICENSEE PERSONNEL CONTACTED The licensee's staff supporting the NRC staff's audit included Mr. Thomas Harding, and Mr. Ken Charland. The NRC staff appreciates the considerable assistance provided by the licensee's staff to facilitate timely completion of the NRC staff's audit.
J.E. Pacher The licensee's staff supporting the NRC staffs audit included Mr. Thomas Harding, and Mr. Ken Charland. The NRC staff appreciates the considerable assistance provided by the licensee's staff to facilitate timely completion of the NRC staff's audit.
If there are any questions, please contact me at (301) 415-14 76 or email mohan.thadani@nrc.gov.
Sincerely, IRA/
Mohan C. Thadani, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
Audit Report Docket No. 50-244 cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrDorlLpl 1-1 RidsNrrPMREGinna LPL 1-1 Reading File RidsNrrLAKGoldstein RidsAcrsAcnw MailCTR RidsNrrDorlDpr RidsRgn1 MailCenter ADAMS ACCESSION NO.: ML15043A716 OFFICE LPL 1-1/PM LPL 1-1/LA LPL 1-1/BC LPL 1-1/PM NAME MThadani KGoldstein BBeasley MThadani DATE 02/19/2015 02/18/2015 02/19/2015 02/19/2015 OFFICIAL RECORD COPY