ML15358A182
| ML15358A182 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/21/2016 |
| From: | Audrey Klett Plant Licensing Branch II |
| To: | Nazar M Nextera Energy |
| Klett, Audrey, NRR/DORL/LPL2-2 | |
| References | |
| CAC MF6787, CAC MF6788 | |
| Download: ML15358A182 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 January 21, 2016
SUBJECT:
TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4-AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (CAC NOS. MF6787 AND MF6788)
Dear Mr. Nazar:
The U.S. Nuclear Regulatory Commission (NRC) staff audits a licensee's commitment management program every 3 years in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC." This office instruction provides the NRC staff and its stakeholders with guidance on managing regulatory commitments and ensures a common understanding of the handling of regulatory commitments made to the NRC staff by licensees for commercial nuclear power reactors.
The NRC staff audited Florida Power & Light Company's (the licensee's) commitment management program during the period from December 7, 2015, to December 23, 2015. The NRC staff concluded that the licensee implemented its commitments on a timely basis, and the licensee implemented an effective program for managing commitment changes. The enclosed audit report contains the details of the audit.
Should you have any questions regarding this matter, please contact me at (301) 415-0489 or Audrey.Klett@nrc.gov.
Docket Nos. 50-250 and 50-251
Enclosure:
Audit Report cc w/enclosure: Distribution via Listserv Sincerely,
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Audrey K'l~tt, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251
1.0 INTRODUCTION AND BACKGROUND
On September 16, 2013, the Office of Nuclear Reactor Regulation (NRR) of the U.S. Nuclear Regulatory Commission (NRC) issued Revision 5 of NRR Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC."1 LIC-105 provides NRR staff guidance on managing regulatory commitments and ensures a common understanding of the handling of regulatory commitments. The guidance is consistent with the Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes,"2 which the NRC staff found acceptable as described in Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff."3 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.
LIC-105 requires that every 3 years, NRR project managers (PM) 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 and the licensee's program for managing changes to its commitments. The audit also determines whether any commitments were misapplied (e.g., whether NRC staff accepted licensee-proposed commitments rather than the necessary regulatory requirement or obligation).
2.0 AUDIT PROCEDURE AND RESULTS An NRR PM audited Florida Power & Light Company's (FPL's, the licensee's) commitment management program from the NRC office in Rockville, Maryland, from December 7, 2015, to December 23, 2015. The NRR PM reviewed commitments made by FPL since the previous NRC audit report dated January 30, 2013.4 The audit consisted of reviewing the licensee's implementation of its commitments, the licensee's management of changes to its commitments, and determining whether any commitments were misapplied. The attachment to this report lists the sample of licensee commitments and the licensing actions audited by the NRR PM. The attachment does not include all commitments the licensee made to the NRC. The NRR PM contacted Ms. Olga Hanek and Ms. Stavroula Mihalakea of the licensee's staff for this audit.
1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML13193A358.
2 ADAMS Accession No. ML003680088.
3 ADAMS Accession No. ML003741774.
4 ADAMS Accession No. ML13023A196.
Enclosure 2.1 Licensee's Implementation of NRC Commitments Audit Scope The audit focused on regulatory commitments made in writing to the NRC as part of licensing actions or activities. The NRR PM reviewed a sample of ten commitments to determine whether the licensee had either implemented closed commitments it made to the NRC or captured commitments in an effective program for future implementation. The NRR PM reviewed documents generated by processes in effect during the scope of the audit and other documents related to commitments.
The NRR PM did not audit commitments made in licensee event reports, responses to notices of violations, confirmatory orders, or confirmatory action letters, if other NRC processes (e.g.,
NRC's Reactor Oversight Process inspection procedures) prescribed separate followup for these items.
Audit Results The NRR PM determined that the licensee's program for implementing and managing commitments is adequate. The licensee uses the following procedures for implementing and managing its commitments: Ll-AA-101-1005, "NRC Commitment Management," Revision 2; Ll-AA-101-1005-10000, "Commitment Tracking," Revision 1; and LDl-01, "NRC Commitment Change Process," Revision 4. The NRR PM concluded that the licensee appropriately implemented the commitments it made to the NRC. The NRR PM reviewed licensee documentation related to commitments made to the NRC and found that the licensee implemented the commitments. The NRR PM found that the licensee's commitment tracking program (i.e., Nuclear Asset Management System) captured regulatory commitments. The NRR PM also determined that the licensee's commitment management system ensured traceability of commitments following initial implementation.
2.2 Licensee's Management of Commitment Changes Audit Scope The NRR PM reviewed the licensee's procedures and program for managing commitment changes to verify the licensee established adequate controls for modifying or deleting commitments made to the NRC. The NRR PM compared the licensee's process for controlling regulatory commitments, which is discussed in the procedures in Section 2.1 of this report, to the guidelines in NEI 99-04. The NRR PM also reviewed modified or deleted commitments that the licensee reported and did not report to the NRC. The NRR PM also determined whether the licensee's commitment management system ensured traceability of commitments following initial implementation to verify that the licensee evaluated proposed changes to affected design features or operating practices in accordance with its commitment change control process.
Audit Results The NRR PM concluded that the licensee established adequate controls for modifying or deleting commitments made to the NRC. The NRR PM concluded that the licensee modified or deleted commitments in accordance with the guidelines in NEI 99-04.
2.3 Review for Misapplied Commitments Audit Scope A commitment is considered to be misapplied if the NRC staff relied on the action comprising the commitment 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 regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, or a 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). The NRR PM reviewed license amendment safety evaluations, exemptions, and relief request safety evaluations issued to the licensee during the previous 3 years to determine if the documents contained any misapplied commitments.
Audit Results The NRR PM did not identify any misapplied commitments in licensing actions from the past 3 years. The licensee did not identify any misapplied commitments to the NRR PM.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit: ( 1) the licensee has implemented or is tracking for future implementation regulatory commitments; (2) the licensee has implemented a program to manage regulatory commitment changes; and (3) the regulatory commitments were not misapplied.
Principal Contributor: Audrey Klett Date:January 21, 2016
Attachment:
List of Audited Commitments and Licensing Actions
LIST OF AUDITED COMMITMENTS AND LICENSING ACTIONS COMMITMENTS Open Commitments:
Licensee Tracking No.
Update EC for Pressurizer (PRZ) Surge Line Weld Inspection Aging 01626907-60-00 Manaqement Proqram (AMP)
Document PRZ Surge Line Weld Inspections for Units 3 01626907-61-00 UFSAR includes NRG-approved PRZ Surqe Line Weld Inspection AMP 01626907-64-00 Update lnservice Inspection Program with Reference of Approved PRZ 01626907-63-00 Surge Line AMP Closed Commitments:
Licensee Tracking No.
Emerqency Containment Cooler Tube Wear 01626907-35-00 Revise Procedures to Support Extended Power Uprate (EPU) 00566443-23-00 Post-Loss-of-Coolant Accident (LOCA) Coolinq Analyses Implementation of NRC-aooroved Surqe Line Inspections 01626907-4 7-00 Bare Metal Visual Inspection - U3 PRZ Heater Sleeve 01958688-02-00 Commitment Changes (to be) Reported to the NRC:
Licensee Tracking No.
Inspection of Reactor Head for Boron Deposits (L-87-186 and 1983926-04 L-2003-007)
Commitment Changes Not Reported to the NRC:
Licensee Tracking No.
Containment Equipment Hatch Door (L-2001-201) 01940205 (EC280781)
LICENSING ACTIONS ADAMS No.
Description Amendments/Exemptions ML15294A443 License Amendment Request (LAR) 212 Emergency Core Cooling System Technical Specification (TS) Chanqe ML15061A237 LAR 216 Transition to NFPA-805 ML13329A092 LAR 217 Miscellaneous Chanaes to Operating License Conditions/TSs ML13059A224 LAR 224 TS 3/4.6.2.3 Recirc pH, NaTB Baskets ML13207A095 LAR 225 TS Surveillance Requirement 4.5.1.1.d ML13329A139 LAR 226 Optimized ZIRLO Fuel Claddinq ML14024A547 LAR 226 Optimized ZIRLO Fuel Cladding (Exemption)
M L15166A320 LAR 229 Technical Specification Task Force (TSTF)-425 ML15181A179 LAR 230 TSTF-523 ML14199A107 LAR 231 Ultimate Heat Sink TS ML15205A174 LAR 233 Remove Reactor Coolant System Chemistry TSs ML15233A379 LAR 234 Cybersecurity Milestone 8 ML12339A112 Cyber Security Plan Implementation Schedule Milestone Change ML13191A085 Revision 15 to Physical Security Plan Relief Requests ML13260A493 4th ISi Interval - Relief Request No. 10 ML13329A120 4th ISi Interval - Relief Request No. 11 ML13329A125 4th ISi Interval - Relief Request No. 12 ML14034A176 4th ISi Interval - Relief Request No. 13 ML14083A216 4th ISi Interval - Relief Request No. 14 ML15328A240 4th ISi Interval - Relief Request No. 15 ML14122A268 5th ISi Interval - Relief Request No. 1 ML15271A325 5th ISi Interval - Relief Request No. 1 (Revised)
ML15328A108 5th IST Interval - Relief Request No. PR-01 Attachment
ML15358A182 OFFICE DORL/LPLI 1-2/PM DORL/LPLI 1-2/LA DORL/LPLI 1-2/BC NAME AKlett (LRonewicz for) BClayton BBeasley DATE 12/29/2015 12/28/2015 1/20/2016