ML15321A102
| ML15321A102 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/16/2015 |
| From: | Martha Barillas Plant Licensing Branch II |
| To: | Waldrep B Duke Energy Progress |
| Barillas M, NRR/DORL, 415-2760 | |
| References | |
| CAC MF6565 | |
| Download: ML15321A102 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 16, 2015 Mr. Benjamin C. Waldrep Site Vice President Shearon Harris Nuclear Power Plant 5413 Shearon Harris Rd.
New Hill, NC 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (CAC NO. MF6565)
Dear Mr. Waldrep:
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 (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 confirm that regulatory commitments are being effectively implemented.
An audit of the Shearon Harris Nuclear Power Plant, Unit No. 1 (Harris) commitment management program was performed at the plant site in New Hill, North Carolina, on October 19 - 22, 2015. The NRC staff concludes, based on the audit, that Harris (1) has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
B. Waldrep Please direct any inquiries to me at 301-415-2760 or Martha.Barillas@nrc.gov.
Sincerely, Martha Barillas, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400
Enclosure:
Audit Report cc w/enclosure: Distribution via Listserv
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS SHEARON HARRIS NUCLEAR POWER PLANT, UNIT N0.1 DOCKET NO. 50-400
1.0 INTRODUCTION AND BACKGROUND
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 (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. 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.
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 confirm that regulatory commitments are being effectively implemented. An audit of the Shearon Harris Nuclear Power Plant, Unit No. 1 (Harris) commitment management program was performed at the plant site in New Hill, North Carolina, on October 19 - 22, 2015. The audit reviewed commitments made since the previous commitment audit completed in July 2012.
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.
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 Enclosure
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. It focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions or licensing activities. 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 its Agencywide Documents Access and Management System 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, 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 Table provides details of the audit and its results.
The NRC staff reviewed the relevant plant procedure to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC. The procedure reviewed was AD-LS-ALL-0010, "Commitment Management," Revision 1. In addition, the NRC staff reviewed a sample of open and closed commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation.
The NRC staff compared the guidance in procedure AD-LS-ALL-0010 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the procedure implemented by the licensee is consistent with the NEI guidance for identifying, managing, and closing commitments. The NRC staff also found that roles and responsibilities and processes were clearly identified in the AD-LS-ALL-001 O procedure.
The licensee's commitments are tracked in a computer database called CAS. Based on reports provided by the licensee of the CAS database during the audit, the NRC staff found that CAS is able to provide the necessary information (e.g., summary of the commitment, commitment type, lead department, responsible individual, due date, extensions, closure method and date, and associated historical information) to effectively manage NRC commitments.
For this part of the audit, the NRC staff reviewed site records associated with commitments involving generic letters, bulletins, and license amendments to determine whether the licensee had implemented the closed commitments appropriately, and whether the licensee had established a success path for future implementation of the open commitments.
The NRC staff reviewed the documentation associated with the closed regulatory commitments, particularly plant procedures that had been revised as a result of the commitments, and found that the commitments reviewed had been closed in a manner that fully satisfied the commitments made to the NRC.
Based on the sample of commitments reviewed, the NRC staff found that commitments tracked in accordance with procedure AD-LS-ALL-0010 were implemented satisfactorily. Also, based on the sample of licensee submittals and the NRC staff safety evaluations reviewed, the NRC staff found that commitments were tracked as specified by procedure. However, the NRC staff identified one instance where a site procedure, although a controlled document, was not traceable to the specific commitment. The licensee entered this in the Harris corrective action program for evaluation as condition report 1967696.
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 Harris is contained in the procedure AD-LS-ALL-0010.
The audit reviewed a sample of commitment changes that included changes that were reported to the NRC. The audit verified 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.
2.3 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. No misapplied commitments were identified for Harris.
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 are reviewed. These documents were evaluated to determine if they contained any misapplied commitments as described above.
The NRC staff reviewed the safety evaluation reports for the completed licensing actions since the last audit, and no misapplied commitments were identified for Harris.
2.4 Audit Results The attached Audit Summary Table also provides details of this portion of the audit and its results.
The NRC staff found that procedure AD-LS-ALL-0010 was consistent with the guidance found acceptable in NEI 99-04. The NRC staff concludes that the procedure used by the licensee to manage commitment changes is appropiate and that the licensee followed the process in its procedure.
The NRC staff reviewed the documentation associated with the changed commitments. The NRC staff observed that Harris had complete records and documented changes appropriately, which ensure the traceability of commitments.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) Harris has implemented NRC commitments on a timely basis, and (2) Harris has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT John Caves - Licensing and Regulatory Programs Sarah McDaniel - Licensing and Regulatory Programs Principal Contributor: Martha Barillas
Attachment:
Audit Summary
AUDIT
SUMMARY
LIST OF COMMITMENTS INCLUDED IN THE AUDIT No. I Cateaorv I Action <Letter No. Letter Date CompletJpn ~ote$
ReqU!St~o. & "'~:? <;;;__ f
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c status Cyber Security 473783 RA-13-1001 12/19/2013 Harris requested change to Milestone NRC approved requested LAR OPEN 8 implementation date in License change in implementation Condition E. Physical and Cyber date to Milestone 8 of Security Harris Cyber Security Plan (ML14318A929). This is a license condition that is open and being tracked for completion in Harris Commitment Management Program.
2 I Emergency 745774 HNP-15-025 4/30/2015 Duke Energy commits to providing a Tracked as an open action Action Levels OPEN review of the new classification item in AR. LAR under LAR scheme to State and local emergency NRC review.
management officials following NRC a roval and rior to im lementation 3 Reactor Vessel 481777 HNP-11-034 8/16/2011 Remove capsule Y or Z at end of NRC approved capsule Capsule OPEN cycle 21 and test per ASTM El85-82. withdrawal schedule withdrawal Report test results to NRC one year change LAR (ML schedule LAR after capsule removal. 11293A076). This is being tracked as an open commitment due to reporting of results to occur at a later date (2018 end of c cle 21 .
4 I Cyber Security 473783 RA-11-011 4/7/2011 Complete Cyber Security Program Milestones 1-7 completed LAR CLOSED Implementation Milestones 1-7 Attachment
No. *c~t,gory. 1 ** Action Letter No. Letter Date & Commitment Completion NQtes
> *. ~<;~ : .. };
Request No. . }; . . **
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5 TSTF-523 LAR 270886 RA-15-0006 6/24/15 Submit TSTF-523 LAR LAR submitted under submittal CLOSED review by staff.
6 Buried Piping 389318 9/27/10 Condition Assessment due date Condition Assessment Condition CLOSED was changed by NEI letter to NRC completed. Buried Piping Assessment (ML103410507) Integrity Program Commitment Implementation in place via procedure AD-EG-ALL-1613.
7 Relief Request 571271 HNP-12-133 12/17/12 Daily operator walkdowns to Code repair completed on 13R-10 Spent monitor leakage. Ultrasonic through wall leaks by due Fuel Pool CLOSED measurements on 30 day intervals date. Work Orders and Cooling Piping to monitor flaw size. Actions to be AR complete.
completed and leak fixed by RFO 18.
8 Metamic Coupon 654622 HNP-14-070 6/23/14 Metamic Coupon dimension Dimension change will Sampling Change/CLOSED changed from 8x6x0.098 (existing) not affect the ability to Program to 8x4x0.098 (new) because Holtec detect bubbling, is no longer producing the existing blistering, cracking, dimensions as described in the flaking or other physical Metamic Coupon Sampling changes. The difference Program Commitment in length of the new coupon will not affect the neutron attenuation capability of the material or affect the ability to monitor Boron areal density changes.
Coupons are only for monitoring the condition of the actual material used in the rack fabrication. Reported in the Summary Report in accordance with Commitment Manaqement Program.
No. Category_ Action Letter No. I Letter Date Commitment Completion Notes I
~equest ,) &,
Status
/
,', ,__ , -~ ~ '> No.
9 License Transfer 735571 RA-14-0029 12/22/14 Notify NRC when closing of Notified NRG via Letter from NCEMPA to CLOSED Acquisition and transfer will occur dated July 29, 2015.
Duke Energy 10 EP Unified 610491 RA-13-012 6/26/13 Will compile design data supporting Commitment Actions RASCAL CLOSED modeling with a multisource/multiple complete.
Interface Program release pathway software code such as Raddose V or multi-source/multiple release point modeling capable version of Unified RASCAL Interface (URI), test the new program, develop relevant procedures, perform training, and complete Implementation by December 31, 2014.
No. Category . ~ttion Letter No. Letter Date & Commitment Completion
.. .. Notes
... .. ReCluest No. . Stattl$ . .. ~; *** *Y:
- 11 NRC Inspection 728016 N/A 2/3/15 Update procedure to ensure The commitment was Report No. 93-11 Changed/Inactivated labeling of Radioactive Material per inactivated because NOV response 10 CFR 20 requirements. licensee recognized this is changed a regulatory requirement, commitment not a commitment and procedure contains requirement to label radioactive material per 10 CFR 20.
12 GSl-191 606863 HNP 5/16/13 Complete any necessary additional WCAP-17788 is under 053 Changed/OPEN insulation measurements based on staff review. The the PWROG's new in-vessel commitment due date was acceptance criteria following the changed subject to when first NRC issues SE. Tracked refueling outage after the NRC as OPEN in AR 606863.
staff's issuance of the safety evaluation for the PWROG Comprehensive Test Program, WCAP-17788.
ML15321A102 OFFICE DORL/LPLll-2/PM DORL/LPLll-2/LA DORL/LP LI 1-2/BC DORL/LPLll-2/PM NAME MBarillas BClayton BBeasley MBarillas DATE 12/09/2015 11/17/2015 12/15/2015 12/16/2015