ML20249C012

Audit Rept Commitment Mgt Southern Nuclear Operating Co Edwin I Hatch Nuclear Plant,Units 1 & 2

ML20249C012
Person / Time
Site:	Hatch
Issue date:	06/22/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20249C008	List: ML20249C007 ML20249C012
References
NUDOCS 9806250176
Download: ML20249C012 (6)

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AUDIT REPORT COMMITMENT MANAGEMENT SOUTHERN NUCLEAR OPERATING COMPANY EDWIN l. HATCH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366

~l. 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 assess licensees' implementation of commitments made to the NRC and also asses 6 the long-term control of commitments as a follow-up to the issuance of industry guidance fr,r evaluating and reporting changes to commitments made to the NRC.

Edwin 1. Hatch Nu(lear Plant, Units 1 and 2 (Hatch), was selected as one of eight facilities whose commitmer t 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 imptove the (1) identification of important licensee commitments or other supporting design features or operational practices used by the licensee to justify a proposed change or address Jesign or operational problems, (2) determination of the most appropriate means for verifying important commitments or other supporting information, 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 Updated Final Safety Analysis Report (UFSAR), program description documents, or docketed correspondence without formal regulatory controls. The findings from the audits will be used in the staff's development of recommendations to the Commission regarding the need for further staff actions in the area of commitment management.

The audit of Hatch was performed from May 5 through May 7,1998, by Leonard N. Olshan, the Hatch Project Manager, Division of Reactor Projects - 1/11, Office of Nuclear Reactor Regulation (NRR). Additional discussions between the licensee and the staff took place by telephone, and additional review of material provided by the licensee was performed in the NRC/NRR offices in Rockville, Maryland. The audit consisted of interviewing personnel and reviewing procedures, guidence documents, and other documentation related to the commitment management proc.'.ss used by the licensee at Hatch. Additional reviews of work records, procedure changes, and other documentation were performed to verify that commitments, and changes to commitments, had been implemented.

II. VERIFICATION OF LICENSEE IMPLEMENTATION OF PAST COMMITMENTS In order to verify that the licensee effectively implements commitments made to the NRC during staff reviews related to licensing actions and licensing activities, the auditor selected a sample of these types of commitments. The auditor's findings regarding the licensee's implementation of the selected commitments are described below.

Enclosure 9906250176 990622 POR ADOCK 05000321 P PH ,

1. The Safety Evaluation (SE) supporting Amendment 132 for Unit 2, issued March 17,1994, stated that the licensee commited to include the attemate Leakage Control System (LCS) in the ASME Code Section XI inservice inspection (ISI) program. The auditor verified that this commitment had been entered in the Commitment Tracking System (CTS) and that the LCS had been entered in the ISI program.

2. The SE supporting Amendments 197 and 138 for Units 1 and 2, issued August 31,1995, stated that the licensee committed that the Control Rod Drive system will function adequately during the insert and withdraw modes. The auditor noted that this commitment had not been entered in the CTS, but was included in the Startup Test Procedure. The auditor verified that the commitment had been implemented and that the implementation of the commitment had been reported to the NRC in the Power Uprate Startup Test Report 4 submitted for Unit i by letter of July 24,1996, and for Unit 2 by letter of March 4,1996.

3. The SE discussed in item 2 above also stated that the licensee committed to monitor the existing instrumentation on the recirculation pump during and after power ascension. The auditor noted that this commitment had not been entered in the CTS, but was included in the Startup Test Procedure. The auditor verified that the commitment had been implemented and that the implementation of the commitment had been reported to the NRC in the Power Uprate Startup Test Report for both units.

4. The SE discussed in item 2 above also stated that the licensee committed to comply with, prior to implementation of the power uprate, the shroud repair criteria established by the Boiling Water Reactor (BWR) Vessels and intemals Project. The inspector noted that this commitment had not been entered in the CTS, but had been entered in the Action item Tracking (AIT) system. By review of appropriate dowmentation, the auditor verified that

' this commitment has been implemented and reported to the NRC in an update of the FSAR.

5. The SE supporting Amendments 185 and 125, issued April 30,1993, stated that the licensee committed to implement formal administrative controls to ensure that operation with a loss of trip, isolation, or actuation instrumentation functional capability is not permitted during a 12-hour allowed out-of-service time. The auditor noted that this commitment had not been entered in the CTS. Licensee personnel told the auditor that they did not enter this commitment in the CTS because the requirement existed in the BWR improved Technical Specdications, which were used as a model for the licensee's submittal. The auditor reviewed the Hatch Technical Speedications to verify that the commitment had been implemented.

6. The SE supporting Amendments 201 and 142, issued June 27,1996, stated that the licensee will continue to monitor ambient drywell temperatures and thet the qualified lifetimes of components will be adjusted as necessary based on the actual temperatures that exist. The auditor verifed that this commitment had been entered in the CTS. By reviewing the Hatch Technical Specifications and the Environmental Qualification Program, the auditor verified that this commitment had been implemented.

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7. The SE supporting Amendments 200 'and 141, issued March 6,1996, stated that the licensee must maintain comparisons of the performance of the overall containment system and the individual components to show that the test intervals are adequate. The auditor verified that this commitment had been entered in the CTS. By reviewing the Hatch Technical Specifications, the auditor verified that this commitment had been implemented.

8. In its January 30,1997, response to the NRC's letter regarding adequacy and availability of design basis information (pursuant to 10 CFR 50.54(f)), the licensee committed to perform two vertical slice system assessments to revalidate design basis programs. The auditor noted that this commitment had not been entered in the CTS, but that a Request for Engineering Assistance (REA) had been written to implement this commitment. The auditor verified that one of the vertical slices had been performed, but that the second one has not yet been completed.

9. In its January 30,1997, response discussed in item 8 above, the licensee also committed to conduct an accuracy verification of the Hatch FSARs. The auditor noted that this commitment had not been entered in the CTS, but that a Hatch FSAR Upgrade Program Plan has been developed to implement this commitment in two phases. The auditor verified that only the first phase had been implemented. The schedule for completion of the second phate had not yet been developed.

10. In its August 30,1996, response to NRC Generic Letter (GL) 96-03, the licensee committed to ensure that, during the spring 1997 Unit 2 outage, suppression pool cleanliness would be maintained at an acceptable level by performing a suppression pool cleaning. The auditor verified that this commitment had been entered in the CTS. By reviewing an intemal document entitled,

• Cleanliness of the Suppression Pool, E.I. Hatch Nuclear Plant, Unit 2, Spring 1997," the auditor verified that this commitment had been implemented.

11. In a letter dated September 3,1997, the licensee committed to confirm during each fuel cycle the validity of the 30 percent analytical limit for Rod Block Monitor (RBM) operability.

The auditor verified that this commitment had been entered in the CTS. The auditor verified that a procedure entitled, "RBM Calibration," had been modified to incorporate this commitment.

12. In its January 27,1997, response to NRC GL 96-06, the licensee committed to prohibit operation of the Unit 2 containment coolers when containment temperatures are above the point where boiling may occur. The auditor verified that this commRment had been entered in the CTS. The auditor also verified that a procedure entitled, ' Miscellaneous Emergency Overrides," had been changed to implement this commitment.

13. In its January 27,1997, response to GL 96-06, the licensee also committed to implement '

appropriate corrective actions for three pipe lines that penetrate containment and are susceptible to thermally induced pressurization. The auditor verified that this commitment n had been entered in the CTS. By review of the appropriate documentation, the auditor g verified that the commitment had been implemented on both units. Implementation on

Unit 2 was reported to the NRC in a letter dated October 20,1997. The letter stated that implementation on Unit 1 was to be completed during the fall 1997 refueling outage, which was in progress at the time the letter was written.

14. In its October 25,1991, letter, the licensee committed to quarterly testing of the Emergency Response Data System (ERDS). GL 93-01, issued March 3,1993, provided an acceptable testing program of the ERDS. The auditor verified that this commitment was entered in the CTS. The auditor also verified that a procedure entitled, " Control and Testing of Emergency Communications Equipment," had been modified to include this commitment.

15. In its September 25,1992, response to GL 92-04, the licensee committed to corrective actions to resolve the issue related to reactor vessel water level instrumentation in BWRs.

The auditor verified that the commitment was entered in the CTS. By review of appropirate documentation, the auditor verified that the commitment had been implemented.

In summary, all 15 commitments selected for audit have been implemented or are in the process of being implemented. However, not all of these commitments were entered in the CTS.

Ill. LICENSEE PROGRAMS FOR MANAGING AND CHANGING COMMITMENTS The primary focus of this part of the audit is to assess the licensee's program and performance related to incorporating controls for implementing and modifying or deleting commitments made to the NRC. The staff's interest in this matter is related to how it is assured that commitments are implemented, how changes to commitments (modifications or deletions) are evaluated, and how the NRC is informed of commitment changes that have safety or regulatory significance.

In 1989, the licensee instituted a computer program called NUCLEIS, which includes the CTS and the AIT system. The procedure for the AIT system was implemented in 1991 and the procedure for the CTS was implemented in 1993. The CTS procedure states that short-term commitments are one-time corrective actions and do not have to be entered in the CTS. That is the reason that not all of the commitments listed in Section 11 above have been included in the CTS. These items are usually entered in the AIT system, unless the licensee believes that implementation of the commitment can be assured by some other means. For example, items 8 and 9 in Section ll were not entered in either the CTS or AIT system because they were being handled by the corporate office and not by the site and that implementation is assured by other intemal processes.

The licensee has no formal procedure for changing or deleting commitments. As will be discussed in the following Section IV, such changes or deletions are rare. The decision to change or delete a commitment is made by the Manager of Nuclear Safety and Compliance (NS&C), who also directs and oversees the process. The licensee personnel interviewed by the auditor believed that, in light of the few changes or deletions that are made and the oversight by the NS&C manager, no formal procedure to make such changes or deletions is necessary.

5-There is, however, a procedure for changing procedures. This procedure requires that the writer review the CTS data base, if it is determined that the proposed procedure change may l . change the resolution of a commitment, the NS&C must review the procedure change to ensure l that it is acceptable. The auditor noted that procedure changes are not annotated to indicate that they have been made as a result of a commitment to the NRC. The licensee said it is considering making such annotations as a future enhancement.

l The auditor finds that the licensee has adequate means to assure recognition that a proposed procedure change could affect a previous commitment to the NRC, although it could be enhanced by the use of annotations in the proced.;,2 discussed above. However, this is not the case for a proposed hardware change. As prey;ously mentioned, one-time corrective actions do not have to be entered in the CTS. For example, if the licensee installed a meter to satisfy a l commitment to the NRC, it would not have to be entered in the CTS. If several years later it was determined that the meter was not needed, it could be removed without recognizing that it had been originally installed to satisfy a commitment to the NRC. The licensee personnel agreed that this could happen, but did not believe it was a safety concem because an evaluation in accordance with 10 CFR 50.59 would have to be performed in order to remove the p meter. The NRC would then be informed of the change in the annual report of changes made under 10 CFR 50.59.

IV. EVALUATION OF COMMITMENT CHANGES The auditor and the licensee were able to identify only two changes that have been made to commitments made to the NRC. The auditor reviewed both changes and the findings regarding the liceasee's evaluation and reporting of the commitment changes are described below:

1. By letter dated, January 26,1984, the licensee committed to a post-accident sampling system (PASS) that provides in-line monitoring. The staff's September 21,1984, SE stated, "The PASS provides in-line analysis for reactor coolant and containment atmospheric l radionuclides, and reactor coolant dissolved hydrogen, chloride and pH.... We find that l these provisions meet Criterion (2) of item II.B.3 in NUREG-0737, and, are, therefore, acceptable." in a March 18,1994, inspection Report, the staff found that the in-line measurement equipment used to analyze reactor coolant for boron concentration, chloride ,

concentration, pH, and conductivity had been out of service for approximately 2 years. The j licensee then changed the PASS program from the use of in-line monitoring to a grab i sample program for performing boron, chloride, and pH analysis of reactor coolant.

The proposed change was entered in the AIT system and a 10 CFR 50.59 evaluation was performed. The licensee determined that a letter to the NRC was not required, but reported the change in the Annual Operating Report for 1996, which was submitted on February 28, 1997. The licensee is also revising the UFSAR to reflect the change. The auditor reviewed )

the documentation associated with this change and found that it was adequate to justify the change.

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2. By letter dated February 25,1994, the licensee stated that it would relocate the Process Control Program (PCP) description from the Technical Specifications to the Quality Assurance Program Requirements section of the FSAR. The staffs March 3,1995, SE reflected this relocation. However, an intemal audit conducted from February 10 through March 12,1997, found that the PCP had not been relocated to the FSAR, but instead had been relocated to the Solid Radioactive Waste Process Control Program Manual. By letter dated July 14,1997, the licensee informed the NRC of this discrepancy and asked for NRC's approval of the relocation of the PCP. The issue is currently being reviewed by the staff.

V. LICENSEE SELF-ASSESSMENT in preparation for the NRC audit, the licensee performed, from March 3 through March 5,1998, a self-assessment of the commitment management system at Hatch. The auditor reviewed the final report and interviewed two of the three people who conducted the self-assessment.

Some of the weaknesses discovered by the auditor were also identified by the self-assessment.

For example, the lack of a procedure for changing or deleting commitments was identifuxi as a weakness. The self-assessment found that " licensee personnel are not confident that the proposed plant change does not impact, in any way, a previously made commitment." The self-assessment recommended that Hatch should consider adopting the commitment change process criteria contained in the NEl guidelines. However, the self assessment stated that the NS&C involvement, and the requirement for NS&C manager review and approval, were considered a strength in the process for changing or deleting commitments.

The licensee told the auditor that the recommendations identified by the self-assessment are currently being evaluated.

VI. CONCLUSIONS /

SUMMARY

The auditor found that the commitment management system for Hatch is strongly geared to ensuring that actions are assigned and completed within established schedules. It appears that Hatch has been successful in this regard since all 15 commitments selected for this audit have been satisfactorily implemented.

l The ability to evaluate subsequent changes to commitments is limited by several factors. There is no procedure for changing commitments, but rather it is left to the discretion of the NS&C manager. Furthermore, since one-time corrective actions are not entered in the CTS, subsequent changes could be made without recognizing that the original corrective action had I

been implemented as the result of a commitment. However, the two changes rev'mwed by the auditor were adequately evaluated by the licensee.

Overall, based on this audit, Hatch appears to have an effective commitment management program.

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