ML16014A757
| ML16014A757 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/27/2016 |
| From: | Pickett D Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| Dougulas Pickett, NRR/DORL | |
| References | |
| CAC MF7006, CAC MF7007 | |
| Download: ML16014A757 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Vice President, Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 January 27, 2016
SUBJECT:
AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS - INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (CAC NOS. MF7006 AND MF7007)
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 Indian Point's Commitment Management Program was performed at the plant site during the period of November 17-18, 2015. The NRC staff concludes, based on the audit, that Entergy has: (1) implemented NRC commitments on a timely basis; and (2) implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Docket Nos. 50-247 and 50-286
Enclosure:
Audit Report cc: Listserv Sincerely,
~"r~
Douglas V. Pickett, Senior 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 REGULA TORY COMMITMENTS ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286
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 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 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 that regulatory commitments are being effectively implemented. An audit of the Indian Point Commitment Management Program was performed at the plant site during the period of November 17-18, 2015. The audit reviewed commitments made since the previous audit performed in December 2012 (Agencywide Documents Access and Management System Accession No. ML13015A190).
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.).
Enclosure 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 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 between December 2012 and November 2015. 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 Audit Summary provides details of the audit and its results. The NRC staff found that the Entergy corporate procedure for managing regulatory commitments, EN-Ll-110, "Commitment Management Program," Revision 7, acceptably implements the NEI 99-04 guidelines, and that the Entergy staff at Indian Point is following the guidance of EN-Ll-110.
The attached Table 1 in the Audit Summary lists the commitments that were audited to verify that the licensee adequately implements and tracks its commitments.
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 Entergy commitment management system is described in the Entergy corporate procedure EN-Ll-110. EN-Ll-110 is based on and implements the recommendations of NEI 99-04. The audit reviewed a sample of commitment changes including changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The audit also 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.
2.2.1 Audit Results The attached Audit Summary provides details of this portion of the audit and its results. The NRC staff found that the Entergy corporate procedure for managing regulatory commitments, EN-Ll-110, acceptably implements the NEI 99-04 guidelines pertaining to commitment changes.
The Entergy staff at Indian Point is following the guidance of EN-Ll-110 with regard to commitment changes. The attached Table 2 in the Audit Summary lists the commitments that were audited to verify the licensee's program for managing changes to NRC commitments.
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.
2.3.2 Audit Results The NRC staff found that the Entergy corporate procedure for managing regulatory commitments, EN-Ll-110, acceptably implements the NEI 99-04 guidelines pertaining to the application of commitments. The staff did not identify any examples of misapplied commitments at Indian Point.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit, Entergy has implemented an effective program for managing NRC commitments, changing commitments, and application of commitments at Indian Point.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT George Dahl, Licensing Principal Contributor: Douglas Pickett Date:
January 27, 201 6
Attachment:
Summary of Audit Results
AUDIT
SUMMARY
TABLE 1 -IMPLEMENTATION OF REGULATORY COMMITMENTS INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 Date of Due Date Commitment Number/Description Commitment Status Commitment/
(letter No.)
10/31/2012 End of IP3 A-10434 - Enhancement items identified within the assessment Complete - Communication (NL-12-142)
Refueling (NL-12-142, Attachment 1) will be further developed as enhancements documented by Outage 18 implementation progresses. Alternate approaches will be letter dated February 20, 2013
(-4/1/15) utilized if prudent (e.g., alternate/new technology, improved (NL-13-036).
capability, cost savings, etc.). These enhancement commitments are subject to change as a result of Diverse and Flexible Coping Strategies (FLEX) developments, advances in technology, and progress in the manner of addressing the need for these enhancements.
04/30/2013 11/03/14 A-10448 - Entergy will perform this assessment (determine the Complete - Staffing assessment (NL-13-070) applicable staffing requirements to address back-up equipment documented by letter dated to support the mitigation strategies required by NRC Order November 3, 2014 (NL-14-132).
Number EA-12-04) as part of the Phase 2 staffing assessment as previously identified in NL-12-054.
04/30/2013 11/03/14 A-10449 - Entergy will identify any appropriate modifications to Complete - Response (NL-13-070) the Indian Point Energy Center (IPEC) Emergency Plan Drill documented in letter dated and Exercise Program upon completion of the mitigation November 3, 2014 (NL-14-132).
strategies and associated guidance being developed in response to NRC Order Number EA-12-04.
Date of Due Date Commitment Number/Description Commitment Status Commitment/
(Letter No.)
04/30/2013 03/05/14 A-10450 - Entergy will incorporate instructions into applicable Complete - Site procedures (NL-13-070) fleet/site guidance for IPEC to activate the expanded response revised to incorporate guidance to capability and to integrate this capability into the existing activate the expanded response augmented emergency response organization structure based capability as described.
upon the following conditions as described in Nuclear Energy Institute (NEI) 12-01, Revision 0, dated May 2012.
- Loss of all offsite and all on-site power sources to AC emergency busses at more than one unit, or
- Plant parameters or conditions require implementation of severe accident management strategies for more than one unit.
06/21/2013 12/31/14 A-10455 - Indian Point Energy Center plans to implement an Complete - Closure date of (NL-13-090) updated computer program which provides for an improved December 30, 2014, documents capability for multi-source dose consequence analysis.
completion of training for ERO personnel.
04/02/2014 Outages Indian Point Unit 2 commits to the following:
Open - An administrative (NL-14-045) when SG Indian Point Unit 2 will apply a factor of 1.75 to the normal operational leakage limit tube operating leakage associated with the tubesheet expansion associated with the Alternate inspections region in the condition monitoring and operational assessment.
Repair Criteria and the 1.75 are Specifically, for the condition monitoring assessment, the leakage factor will be established performed component of leakage from the prior cycle from below the H*
for the refueling outage in which a distance will be multiplied by a factor of 1. 75 and added to the SG inspection is performed total leakage from any other source and compared to the following approval of the license allowable accident induced leakage limit. For the operational amendment request.
assessment, the difference in the leakage between the allowable leakage and the accident induced leakage from sources other than the tubesheet expansion region will be divided by 1. 75 and compared to the observed operational leakage. An administrative limit will be established to not exceed the calculated value.
AUDIT
SUMMARY
TABLE 2 - CHANGES TO REGULATORY COMMITMENTS INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 Commitment Due Date Commitment Number/Description Commitment Change A-10450 3/5/2014 A-10450 - Entergy will incorporate instructions into applicable By letter dated February 27, 2014 Letter dated fleet/site guidance for IPEC to activate the expanded response (NL-14-034), the implementation 4/30/2013 capability and to integrate this capability into the existing date was changed from 31512014 (NL-13-070) augmented emergency response organization structure based to 6/25/2014. Reasons cited were upon the following conditions as described in Nuclear Energy to not interfere with the IP2 Institute (NEI) 12-01, Revision 0, dated May 2012.
refueling outage of March 2014 Loss of all offsite and all on-site power sources to AC and to remain consistent with fleet emergency busses at more than one unit, or activities. Revised implementation
- Plant parameters or conditions require implementation date was met. Commitment is of severe accident management strategies for more complete.
than one unit.
A-10375 The end of A-10375 - Install manways in the EOG air accumulators, The work was not completed as the IP3 RFO prepare the internal surfaces, repair as required and then coat planned. On March 24, 2013, the in March the inside of the vessels with an epoxy to minimize any commitment was rescheduled for 2007 additional wall thinning and to prevent further corrosion. This completion during the March 2015 work is expected to be completed during the next Unit 3 refuel RFO.
outage in March 2007.
A-10375 The end of A-10375 - Install manways in the EOG air accumulators, The work was not completed as the IP3 RFO prepare the internal surfaces, repair as required and then coat planned. On March 16, 2015, the in March the inside of the vessels with an epoxy to minimize any commitment was rescheduled for 2015 additional wall thinning and to prevent further corrosion. This completion during the March 2017 work is completed on EOG 32 and 33 and the epoxy coating of RFO.
EOG 31 is expected to be completed during the next Unit 3 refueling outage (3R 18) in March 2015.
Commitment Due Date Commitment Number/Description Commitment Change A-10375 The end of A-10375 - Install manways in the EOG air accumulators, Commitment remains open.
the IP3 RFO prepare the internal surfaces, repair as required and then coat in March the inside of the vessels with an epoxy to minimize any 2017 additional wall thinning and to prevent further corrosion. This work is completed on EOG 32 and 33, is partially completed on EOG 31, and the epoxy coating of EOG 31 is expected to be fully completed during the next Unit 3 refueling outage (3R 19) in March 2017.
P-8699 Historic - no P-8699 - The UFSAR stated that a safety analysis and change Commitment cancelled on March specific due may be made to the Interim Radwaste Storage Facility to 20, 2015. The Interim Radwaste date permit the storage of waste oil and that a preliminary risk Storage Facility has been evaluation would be performed to support a formal 50.59 converted to the FLEX equipment analysis.
storage building and will not store radwaste or waste oil.
A-10390 June 30, A-10390 - Full implementation of the cyber security plan (i.e.,
Commitment open.
2016 Milestone 8) will occur on December 15, 2014.
Implementation of the cyber security plan is a license condition.
By amendments dated December 11, 2014, the implementation date was changed to June 30, 2016. A current license amendment application proposes to defer implementation to December 31, 2017.
effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286
Enclosure:
Audit Report cc: Listserv DISTRIBUTION:
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