ML15313A108
| ML15313A108 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/01/2015 |
| From: | Render D Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| Render D | |
| References | |
| CAC MF6785 | |
| Download: ML15313A108 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Vice President, Operations Entergy Nuclear Operations, Inc.
December 1, 2015 James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - AUDIT OF ENTERGY'S MANAGEMENT OF REGULATORY COMMITMENTS (CAC NO. MF6785)
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," 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 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 James A. FitzPatrick Nuclear Power Plant's Commitment Management Program was performed at the plant site during the period of October 28-29, 2015. The NRC staff concludes, based on the audit, that the licensee has implemented regulatory commitments on a timely basis, and has implemented an effective program for managing regulatory commitment changes. Details of the audit are set forth in the enclosed audit report.
If you have any questions, please feel free to contact me at 301-415-3629.
Docket No. 50-333
Enclosure:
Audit Report cc w/encl: Distribution via Listserv
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Diane Render, Project Manager Plant Licensing Branch 1-1 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 ENTERGY NUCLEAR OPERATIONS. INC.
JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
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 (Agencywide Documents Access Management System (ADAMS) Accession No. ML003741774), 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. 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 the 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 James A. FitzPatrick Nuclear Power Plant's (JAFNPP) Commitment Management Program was performed at the plant site during the period of October 28-29, 2015. The audit reviewed commitments made since the previous audit on December 11-13, 2012 (ADAMS Accession No. ML13030A127).
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 Enclosure 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 p'ersonnel 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 and Technical Specifications (TSs). 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 found that Entergy has implemented their commitments on time or before their initial due dates. NRC staff also was able to track any changed commitments through their commitment management program, and determined that future changes will be easily tracked through this effective program.
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 JAFNPP is contained in the Entergy Nuclear Operations, Inc. Commitment Management Program Procedures, EN-Ll-110, Revision 7. 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 commitment management program contains commitments established and lists detailed information on how to track the changes to any commitments with their records management system and corrective action program. The NRC staff also found that the licensee's commitment management program is consistent with NEI 99-04 guidelines.
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.
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 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.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that Entergy has implemented regulatory commitments on a timely basis and has implemented an effective program for managing regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Mark Hawes Principal Contributors: Diane Render Date:December 1, 2015
Attachment:
Summary of Audit Results
Summary of Audit Results Audit of Management of Licensee's Commitment Management Program James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 CA= Corrective Action, LRS = Learning Research System (Commitments Management Database System), LO-LAR = Learning Objectives - Licensing Action Request Licensee's Letter/Date/
Commitment Commitment No.
Oocument(s) Reviewed Status/Notes Entergy commits to use interim staff JAFP-13-0006 Located commitment in LRS.
Scheduled completion by guidance JLD-ISG-2012-05, Guidance 3/12/2017 For Performing The Integrated 1/29/2013 Tracked commitment through Assessment For External Flooding, record management system and OPEN Revision 0, guidance as the approach for A-18477 located original submittal to the developing the NTIF 2.1 Flooding NRC.
Integrated Assessment Report for James A. FitzPatrick if the reevaluated flooding hazard is not bounded by the current design basis flooding evaluation.
Entergy commits to using the guidance JAFP-13-0006 Located commitment in LRS.
Scheduled completion by provided in NRC Letter, D.L. Skeen 3/12/2017 (NRC) to J.E. Pollock (NEI), Trigger 1/29/2013 Tracked commitment through Conditions for Performing and Integrated record management system and OPEN Assessment and Due Date for Response, A-18478 located original submittal to the regarding the trigger conditions and scope NRC of any required Integrated Assessment.
In response to Enclosure 1 OF NRC JAFP-13-0056 Located commitment in LRS.
Due dates are listed in the letter, Request For Information Pursuant NEI letter and have To Title 10 of the Code Of Federal 4/29/2013 Tracked commitment through separate milestones to be Regulations 50.54(f) regarding corrective action program.
completed.
Recommendations 2.1, 2.3, and 9.3, of A-18479 the near-term task force review of insights Viewed LO-LAR-2012-0082 from the Fukushima Dai-ichi Accident, dated March 12, 2012, Entergy intends to follow the approach described in Nuclear Energy Institute (NEI) letter to the NRC, proposed path forward for NTIF Recommendation 2.1: Seismic Reevaluations, dated April 9, 2013.
In response to NEI letter, Commitment for JAFP-13-0089 Located commitment in LRS.
Scheduled completion dates Implementation of Multi-Unit Dose of the following: 12/31/2014; Assessment Capability, from NEI to the 6/27/2013 Tracked commitment through 02/06/2014; 04/17/2014; NRC, dated March 14, 2013; Entergy will corrective action program.
04/17/2014; 12/31/2014; implement a permanent process to A-18480 12/31/2014; integrate NMP dose assessment Viewed actions listed under LO-information with JAF dose assessment LAR-2013-00174.
Closed on the following:
information as appropriate.
12/23/2014; 02/05/2014; 04/15/2014; 04/15/2014; 12/23/2014; 12/23/2014 Attachment Licensee's Letter/Date/
Commitment Commitment No.
Document(s) Reviewed Status/Notes Perform a relay chatter review to support JAFP-14-0128 Located commitment in LRS.
Due dates 06/30/2017 and IPEEE focused scope margin assessment 12/31/2019; per SPID in accordance with NEI letter, 12/5/2014 Tracked commitment through "Relay Chatter Reviews For Seismic corrective action program.
OPEN Hazard Screening", dated October 3, A-18482 2013 Viewed actions listed under LO-LAR-2012-00082; CA-00051 and CA-00052 Entergy will perform seismic walkdowns at JAFP-14-0143 Located commitment in LRS.
Due date 10/15/2016; JAF for inaccessible items listed in Section 7.1.
12/30/2014 Tracked commitment through OPEN corrective action program.
A-18484 Viewed actions listed under LO-LAR-2012-00082; CA-00053 Entergy will generate HCLPF calculations JAFP-14-0143 Located commitment in LRS.
Due date 1/10/2017; for inaccessible items listed in Section 7.1.
12/30/2014 Tracked commitment through OPEN corrective action program.
A-18485 Viewed actions listed under LO-LAR-2012-00082; CA-00054 Entergy will implement any necessary JAFP-14-0143 Located commitment in LRS.
Due date 10/31/2018; JAF modifications for inaccessible items listed in Section 7.1 based on the 12/30/2014 Tracked commitment through OPEN schedule commitment to complete this corrective action program.
activity in JAFP-13-0056 dated April 29, A-18486 2013.
Viewed actions listed under LO-LAR-2012-00082; CA-00039 Entergy will submit a letter to NRC JAFP-15-0094 Located commitment in LRS.
Due date 10/31 /2018; summarizing the JAF HCLPF results and confirming implementation of the plant 8/4/2015 Tracked commitment through OPEN modifications associated with the JAF corrective action program.
commitments made by the attachment to A-18489 Entergy letter dated December 30, 2014, Viewed actions listed under LO-JAFP-14-0143.
LAR-2012-00082; CA-00039 Entergy will perform inspections of JAFP-12-0135 Located commitment in LRS.
Closed on 12/1/2014 equipment that could not be inspected as identified in Section 7.5 of the Flooding 11/27/2012 Tracked commitment through the Walkdown Report.
corrective action program and the A-18475 records management program and found the original submittal (JAFP-12-0135) to NRC and then the last submittal (JAFP-14-0121) on 10/30/2014 for the extension of the final date of 12/30/14. LO-LAR-2012-00082; CA-00050
ML15313A108 OFFICE DORL/LPLl-1/PM DORL/LPLl-1 /LA NAME DRender KGoldstein DATE 11/12/2015 11/12/2015 DORL/LPLl-1 /BC TTate 11/19/2015