ML20236R379

Audit Rept,Commitment Mgt Centerior Svc Co for Perry Nuclear Plant,Unit 1

ML20236R379
Person / Time
Site:	Perry
Issue date:	07/10/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236R373	List: ML20236R371 ML20236R379
References
NUDOCS 9807210419
Download: ML20236R379 (9)

Text

_ - _ _ - _ _ _ _ _ _ _ - - _ . _ _ _ _ - _ - - - _ _ _ - _ - _ - - - - - _ _ - _ . - _ - - _ _ _ _ - _ _ - - - - -

y%

l ff +4 UNITED STATES

j. :s 2

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001

%...... /

AUDIT REPORT COMMITMENT MANAGEMENT

)

l CENTERIOR SERVICE COMPANY I PERRY NUCLEAR POVER PLANT, UNIT NO.1 DOCKET NO. 50-440

1. INTRODUCTION As part of the staffs activities related to improving the management of licensing basis information, audits of commitment management programs have been performed at eight reactor facilities. The audits assessed licensees' implementation of commitments made to NRC and also assessed the long-term control of commitments as a follow-up to the issuance of industry guidance for evaluating and reporting changes to commitments made to the NRC.

Perry Nuclear Power Plant, Unit 1 (PNPP) was selected as one of eight facilities whose commitment management programs were audited by the staff.

The audits and other staff efforts related to managing licensee commitments made to the NRC  !

are intended to improve the (1) identification of important licensee commitments or other supporting design features or operating practices used by the licensee to justify a proposed change or address design or operational problems, (2) determination of the most appropriate a means by which important commitments or other supporting information should be verified, and (3) determination of the appropriate placement of the information within the various licensing basis documents associated with the affected facility (i.e., the license or technical specifications, the FSAR, program description documents, or docketed correspondence without formal regulatory controls). The findings from the audits will be used in the staffs development of recommendations to the Commission regarding the need for further staff actions in the area of commitment management.

The audit at PNPP was performed by Douglas Pickett of the Division of Reactor Projects, Office i of Nuclear Reactor Regulation, during the period of May 11 through May 14,1998. Additional j discussions between the licensee and staff and additional in-office review of material provided by the licensee were performed from the NRC/NRR offices in Rockville, Maryland. The audit cor.sisted of interviewing personnel and reviewing procedures, guidance documents, and other documentation related to the commitment management process at PNPP. Additional reviews l of work records, procedure changes, and other documentation were performed to verify the l

implementation of specific procedures or to evaluate changes made to commitments previously made to the NRC.

l 9807210419 900710 PDR ADOCK 05000440 P PDR

11. VERIFICATION OF LICENSEE IMPLEMENTATION OF PAST COMMITMENTS in order to verify that the licensee effectively implements those commitments made to the NRC during staff reviews related to licensing actions and licensing activities, the auditor selected a sample of commitments made during interactions between the licensee and NRR personnel.

The licensee's computer program to track commitments is called the Perry Regulatory Information Management System (PRIMS). The PRIMS code has been used by the licensee since original plant startup. It includes a number of tracking fields including formal commitment number, status, priority, lead individual, source document information, keywords, and text input.

Text input includes a Summary, Commitment Text, Comments, Activities, and Related Documents. The Summary field is generally limited to a single line describing the source of the commitment and the Commitment Text field is generally a verbatim identification of the documented commitment. While the Comment field is available for extended descriptive information, the auditor observed that its use was generally left to the preference of the cognizant individual and the amount of descriptive detail varied widely between individual commitments. Word searches could be performed from any of the Summary, Commitment Text, or Comment fields.

The auditor's findings regarding the licensee's implementation of the selected commitments are described below:

GENERIC LETTER 96-06 Generic Letter 96-06, " Assurance of Equipment Operability and Containment Integrity During Design-Basis Accident Conditions," required, in part, that licensees evaluate the potential for thermal expansion and overpressurization of piping systems penetrating containment.

Commitment Nos.1 through 4 reflect this issue.

1) in the licer;see's letter of January 28,1997, the licensee stated that 11 penetrations were considered susceptible to thermal expansion and overpressurization and were still being evaluated. One of their commitments stated that long-term solutions would be compared with generic industry activities and partnerships, such as NEl, EPRI, BWROG.

A review of the licensee's files indicated attendance at an industry working group meeting in Charlotte, North Carolina on February 27-28,1997, and ongoing discussions with NEl. Long-term solutions for the 11 penetrations were provided to the staff by letter dated May 30,1997. Thus, the commitment appeared to be satisfactorily implemented.

(License's commitment No. LO2315)

2) The licensee's followup letter to Generic Letter 96-06 dated May 30,1997, contained a commitment to evaluate any RF06 local leak rate test results relating to these 11 penetrations to determine its impact on operability.

The PRIMS database referenced an intemal memo that provided a status of the 11 penetrations. Two of the 11 penetrations were modified for relief protection during RF06. Due to the implementation of Option B to 10 CFR 50, Appendix J, local leak rate

~

testing was deferred for five of the penetrations. The remaining penetrations were leak tested during RF06. Since the penetrations were not leak tight, the memo concluded that they would not overpressurize due to thermal expansion.

The above conclusion (i.e., penetration leakage prevents overpressurization) should be appropriate provided that minuscule leakage from temporary test boundary valves or test equipment is not inadvertently attributed to an otherwise leak-tight penetration.

Outside of this concern, the auditor concluded that local leak rate testing during RF06

was considered for operability and the commitment was properly implemented.

! (Licensee commitment No. LO2332)

3) The licensee's followup letter to Generic Letter 96-06 dated May 30,1997, contained a commitment stating that pending availability of qualified components, the modifications l

on the two penetrations that have been analyzed as acceptable based on Appendix F of Section lli of the ASME Code, will be implemented during the sixth refueling outage (Fall 1997).

A review of the PRIMS system indicated that the appropriate modifications were made l to both penetrations during the sixth refueling outage. Therefore, the commitment appeared to be properly implemented. (License commitn.ent No. LO2333)

4) The licensee's followup letter to Generic Letter 96-06 dated May 30,1997, contained a commitment to fully resolve all issues related to the generic letter no later than startup following the seventh refueling outage.

The seventh refueling outage has not occurred and is scheduled for April 1999. A review of the PRIMS system indicates that final resolution of issues related to GL 96-06 is being deferred to the seventh refueling outage. The commitment status is identified as being "open" which is appropriate. The tracking of this commitment N therefore considered proper. (Licensee commitment No. LO2334)

DRYWELL LEAK RATE TESTING License Amendment No. 88, issued on September 24,1997, revised the frequency of performing the drywell bypass leakage test from once every refueling outage to once every 10 years based on performance testing. Commitments 5 and 6 reflect this issue.

5): The licensee's commitment to perform a qualitative assessment of drywell bypass leak tightness once every refueling cycle was critical to the staffs acceptance of the revised test frequency. The assessment would involve pressurizing the drywell via the combustible gas control system in order to verify that a differential pressure could be established between the drywell and the containment. Development of a differential pressure of approximately 1 psid would demonstrate that gross leakage was not present and that overall drywell integrity was being maintained.

A review of the PRIMS database provided a detailed discussion of the purpose of the qualitative assessment and how it would be performed. The auditor verified that USAR

I l

4 section S1B was updated to reflect this commitment. Surveillance instruction (SVI) T23-T0401 was also verified to include the acceptance criteria for performing the qualitative assessment. In addition, the SV1 included a reference to the commitment to maintain traceability. The auditor concluded that the commitment was adequately implemented.

(Licensee commitment No. LO2323)

6) A visual inspection of the exposed accessible interior and exterior surfaces of the i drywell is required to be performed at least 3 times within a 10-year inservice testing interval (prior to performance of each Type A test of the containment) in accordance with Technical Specification surveillance requirement 3.6.5.1.2. During the staff review of the amendment application, the licensee's letter dated December 6,1996, committed to maintain the same frequency of performing the visual inspections, even though the Type A test frequency was reduced to once every 10 years by Option B to 10 CFR 50, Appendix J.

A review of PRIMS referenced revisions to the ISI surveillance instruction regarding visualinspection of the drywell. The auditor examined the surveillance instruction and verified that visual inspections are required 3 times every 10 years as discussed above.

The commitment appeared to be properly implemented. (Licensee commitment No.

LO2321)

TORNADO MISSILE PROTECTION The architect engineer (AE) inspection of early 1997 identified a number of unreviewed safety questions. When the facility unexpectedly shut down in June 1997, a number of actions were required in order to permit plant restart. The licensee's letter of June 13,1997, included a number of commitments agreed to by the licensee to support plant restart. One of the subject areas included the adequacy of the plant's tomado missile protection system. The USAR stated that tomado missile protection was being provided for safety-related components.

However, the AE team identified selected safety-related components that were not protected from tomado generated missiles. Commitment Nos. 7 through 13 were made regarding this issue:

7) In the licensee's letter dated June 13,1997, they committed to the following long-term actions prior to restart from the sixth refueling outage: 1) The methodology to be used for the final resolution of the tomado missile issue will be determined, either through compliance with the current PNPP licensing bases, incorporation of the probability of j tomado missile damage methodology, or a combination of both, and 2) If the probability of tomado missile damage methodology is used, it will be evaluated in accordance with ]

10 CFR 50.59. If the 10 CFR 50.59 evaluation dictates, a license amendment will be submitted to the NRC in accordance with 10 CFR 50.90.

By letter dated August 14,1997, the licensee submitted a license amendment application in accordance with 10 CFR 50.90 that requested a change to the licent!ag basis regarding tomado missile protection. The licensee proposed incorporation of a tornado missile strike probability analysis using the EPRI developed TORMIS computer program. License amendment No. 90, dated November 4,1997, approved the

5 licensee's request. Based on these actions, the auditor confirmed that the licensee implemented the above commitment. (Licensee commitment No. LO2342)

8) In the licensee's letter dated June 13,1997, they committed to install physical barriers to provide protection to components considered vulnerable to tomado missile damage prior to restart.

This was a one-time commitment thet was subsequently resolved through issuance of License Amendment No. 90 as described in item 7 above. A review of the PRIMS system referenced temporary modifications that placed physical barriers around components considered vulnerable to tomado missiles. This was a one-time commitment that was terminated when the staff approved the probability approach in License Amendment No. 90. The commitment appeared to be properly implemented.

l (Licensee commitment No. LO2343) I l

9) In the licensee's letter. dated June 13,1997, the licensee committed to maintain instructions in place for control room operators to transfer the HPCS/RCIC suction line from the condensate storage tank to the suppression pool when a tomado is sighted in the immediate vicinity of the plant.

PRIMS referenced revisions to the appropriate off-normal procedure to realign the suction paths whenever a tomado is sighted in the plant vicinity. The auditor reviewed the applicable procedure and concluded that the commitment was properly implemented. (Licensee commitment No. LO2344)

10) Licensee commitment No. 02344 (item 9 above), revised off-normal proceduree.e realign the HPCS/RCIC suction paths from the condensate storage tank to the suppression pool whenever a tomado is sighted in the vicinity of the plant. As a result of staff concems, the licensee's letter dated October 1,1997, revised this commitment to realign this suction path when the Control Room is notified of the issuance of a tomado waming for the vicinity of the Perry plant.

PRIMS referenced Off-Normal Instruction ONI-ZZZ-1, "Tomado or High Winds," that was revised as a result of this commitment. The auditor reviewed the procedure and concluded that the commitment was appropriately implemented. (Licensee commitment No. LO2356).

11) in a letter dated August 14,1997, the licensee submitted a license amendment

. application to incorporate the TORMIS methodology to determine the systems and components that are required to have physical protection from tomado generated missiles. In that application the licensee committed to incorporate certain USAR changes in accordance with 10 CFR 50.71 following staff approval of the methodology.

This commitment was tracked as Licensee commitr.1ent No. LO2357. (See item 12 below)

12) During the staff's review of the August 14,1997, application to incorporate the TORMIS methodology, the staff requested that additional information be included in the USAR

6-1 update. This included lists diihe plant systems or components that were analyzed. The licensee's letter dated September 26,1997, included a commitment to update the USAR to include this additional information. This commitment, which was an expansion to item j 9 discussed above, was tracked separately as Licensee commitment No. LO2358.

PRIMS identified a number of USAR pages that were updated to incorporate the TORMIS missile protection methodology for Licensee commitment Nos. LO2357 and j LO2358. The auditor reviewed the applicable USAR pages and verified that they were j appropriately updated. The commitments appeared to be appropriately implemented.

13) License Amendment No. 90, issued on November 4,1997, revised the design basis as described in the USAR by adding a description of the TORMIS methodology utilized for determining the systems and components that are considered to require physical protection from tomado generated missiles. The licensee tracked a separate commitment no. LO2361 to review the license amendment and verify that all previous commitments were fully implemented. The auditor concluded that the commitment was ,

properly implemented. (Licensee commitment No. LO2361)

OTHER LICENSING ACTIONS

14) Generic Letter 95-07, " Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves," included, in part, requirements to identify and propose corrective actions for gate valves considered susceptible to pressure locking and thermal binding. !n the licensee's response of February 13,1996, they declared that the residual heat removal (RHR), low pressure core spray (LPCS), and high pressure core spray (HPCS) systems are considered inoperable for their safety function whenever they are aligned to a secondary mode of operation (e.g., RHR being aligned to the suppression pool cooling mode of operation, etc.). The licensee's letter referenced System Operadon Instructions (SOls) for each of the RHR, LPCS, and HPCS systems and they treated these statements as a licensing commitment.

The auditor reviewed sol-E12, ' Residual Heat Removal System (Unit 1)," SOI-E21,

" Low Pressure Core Spray System (Unit 1)," and SO!-E22A, "High Pressure Core Spray System (Unit 1)." All three SOls were verifiexf to include statements saying that the systems were considered inoperable when aligned in a secondary mode of operation.

However, some minor discrepancies were observed in referencing the commitment number. The licensee's practice is to include reference to the commitment in both the text and in the Reference section at the end of each sol. While this was observed to be done for sol-E22A, sol-E21 did not reference the commitment in the text and sol-E12 did not include references to the commitment in either the text or Reference section. A discussion between the auditor and a precedure writer provided assurance that their system had checks to ensure that traceability was being maintained to the commitment. j l

Planned revisions to the Sois included restoring the proper references to the commitment. The auditor considere'. this acceptable. (Licensee commitment No.

LO2329).

7

15) License Amendment No. 86, issued on September 9,1997, revised the Technical Specifications to permit use of Option B,

• Performance-Based Requirements," to 10 CFR 50, Appendix J,

• Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." In the licensee's application to incorporate Option B, the licensee h

committed to establish a leakage rate testing program in accordance with the recommendations of Regulatory Guide 1.163,

• Performance-Based Containment Leak-Test Program."

PRIMS referenced a number of procedures / instructions that were revised to reflect the requirements of Option B. The auditor examined a number of these surveillance instructions and determined that they had been updated to reflect Option B and that the commitment number was referenced in the instructions. The commitment appeared to be properly implemented. (Licensee commitment No. LO2354)

16) License Amendment No. 87, issued on September 11,1997, revised the Technical Specifications to permit increasing the maximum allowable leakage of one or more main steam lines to 35 standard cubic feet per hour provided that the combined leakage of all four main steam lines remain below 100 standard cubic feet per huur.

PRIMS referenced the surveillance instructions that were revised as a result of the above license amendment. The auditor reviewed the appropriate surveillance and concluded that they were appropriately revised. The commitment appeared to be properly implemented. (License commitment No. LO2355)

17) License Amendment No. 91, issued on November 7,1997, revised Technical Specification 2.0, Safety Limits, and Technical Specification 5.6.5, Core Operating limits Report, to incorporate the safety limit minimum critical power ratio for Cycle 7 operation.

PRIMS referenced revisions to the Core Operating Limits Report (COLR) and the auditor verified that the COLR was modified accordingly. Therefore, the commitment appeared to be properly implemented. (Licensee commitment No. LO2362)

18) In the licensee's letter dated June 12,1997, the licensee committed to provide the inspection plan for the core shroud inspection at least 3 months prior to the start of the outage. The licensee plans to perform the core shroud inspection during the seventh refueling outage that is currently scheduled to begin in April 1999. Thus, the inspection plan is scheduled to be submitted in approximately January 1999.

PRIMS identifies the commitment and lists the status as "open." The commitment tracking status appears appropriate. (Licensee commitment No. LO2346) 111. LICENSEE PROGRAMS FOR MANAGING (CHANGING) COMMITMENT,5 The primary focus of this part of the audit was to assess the licensee's programs and performance related to implementing controls for modifying or dPeting commitments made to the NRC. The staff's interest in this matter is related to how thanges to commitments

te

i .g.

l l (modifications or deletions) are evaluated and how the NRC is informed of commitment l changes that have safety or regulatory significance, i

l In SECY-95-300, dated December 20,1995, the staff informed the Commission of its activities I with regard to docketed commitments made by the licensee and acceptable methods for changing these commitments. in this regard, the staff informed the Commission that it intended to notify the Nuclear Energy institute (NEI) by letter that its guidance document " Guideline for

- Managing NRC Commitments" is an acceptable guide for licensees to follow for managing and

- changing their commitments to the NRC.

- The licensee's Plant Administrative Procedure (PAP) - 610, " Regulatory Commitment Tracking Program", describes the responsibilities and program for tracking regulatory commitments.

PAP 410 was modified in September 1997 to adopt the NEl recommendations of " Guideline for ihnaging NRC Commitments.*

l PAP 410 includes guidance for identifying, changing, and closing out regulatory commitments.

l Attachment 2 to PAP 410, " Commitment Change Evaluabon Summary," directs individuals to ,

the processes of 10 CFR 50.59,10 CFR 50.92, or 10 CFR 50.54 as appropriate. PAP 410 was reviewed and appears to have effectively adopted the NEl recommendations and provides 1 guidance as to when the NRC should be informed of commitment changes.

IV. EVALUATION OF COMMITMENT CHANGES

(

The licensee's practice is to maintain and implement all regulatory commitments. As a result, commitment changes are rare. The auditor did not identify any revisions to regulatory commitments since PAP 410 was revised in September 1997 to adopt the NEl guidelines. In addition, licensing personnel were unable to recall any significant commitment changes prior to that date. Therefore, the auditor was unable to evaluate commitment changes performed by the licensee.

V. LICENSEE SELF-ASSESSMENTS in preparation for the NRC audit, the licensee performed a self-assessment of the commitment management system at PNPP. The self-assessment included an in-depth review of plant procedures, the NEl guidance, and 32 regulatory commitments made over the past 2 years.

The auditor discussed the self assessment with licensing personnel and the principal author of the self-assessment.

The licensee's self-assessment concluded that the current process for controlling commitments made to the NRC is in accordance with the guidance provided by NEl and is being effectively implemented. In general, the self-assessment team found that commitments are clearly identified in correspondence with the NRC and that the PRIMS database accurately reflects the commitments. In addition, the self-assessment team concluded that the PRIMS database contains sufficient information to trace the history of the issue, evaluate completion of the activity, and confirm that the intent of the commitment was satisfied. While the self-assessment team noted a backlog in final closeout of commitment activities (i.e., technical work would be

complete but closeout documentation was not done), recent improvement in closure activities were noted.

VI. CONCLUSIONS /

SUMMARY

The PRIMS database currently tracks over 13,000 commitments and does not differentiate between one-time only commitments and those that are continuing. The auditor observed that

)

commitments are clearly identified in licensing correspondence and the PRIMS database. The l

commitments reviewed clearly identified the commitment, associated correspondence and any documentation requiring change (e.g., surveillance, USAR, etc.). Procedures or surveillance that were modified as a result of a commitment clearly reference the commitment for traceability. No discrepancies were identified by the auditor.

The audit concluded that the commitment tracking system at PNPP incorporates the recommendations of the NEl guidance and is effectively implemented. The licensee's procedures, PAP-610, provides clear guidance regarding identification, tracking, changing and closecut of commitments.

i l

I l

E_______________________ ._ _ . . _ . _ _