ML20249C825
| ML20249C825 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/26/1998 |
| From: | Bajwa S NRC (Affiliation Not Assigned) |
| To: | James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| NUDOCS 9807010266 | |
| Download: ML20249C825 (14) | |
Text
_ _ _ _ _ - ._. ___ __ _ __ _ _ _ - - _ - _ _ - _ _ _ _ _ - - _ ____ _
,_ .. ' Mr. J:m:s Knub:l l Turie 26,1998.
Chief Nucirr Officer "
Power Authority of tha St:12 of -
Y ' New York :
123 Main Street 4 White Plains, NY 10600
SUBJECT:
NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
Dear Mr. Knubel:
The enclosed report provides the results of an audit conducted by the Office of Nuclear Reactor Regulation (NRR) of the commitment management prugram at the James A. FitzPatrick Nuclear Power Plant. The insights gained from the audit at this facility will be used, along with the results from similar audits of seven other licensees' commitment management programs, to determine what, if any, changes to NRC poficy or regulations are warranted. In addition, the staff has undertaken discussions with the Nuclear Energy Institute (NEI) to determine if changes in their guidance document, " Guideline for Managing NRC Commitments," might be mutually beneficial forlicensees and the NRC staff. The staff's efforts and recommendations in this area will be 4 : presented in reports to the Commission later this year.
Overall, the FitzPatrick comm;tment management program was found to be adequate. The audit found that commitment changes have been reported to Nik consistent with the NEl guidance.
Planned procedure revisions should improve documentation of the critical thought processes used to disposition an item. The audit also found that commitment closure documentation was adequate to determine basis for action.
We thank your licensing staff and other personnel who participated in the audit for their cooperation. If you have any questions or comme.r,ts conceming this report or the related efforts to improve NRC and industry guidance in the area of commitment management, please contact Joe Williams at (301) 415-1470 or Williarn RecHey at (301) 415-1314.
Sincerely, Original Signed by:
S. Singh Bajwa, Director Project Directorate 1-1 Division of Reactor Projects -l/II Office of Nuclear Reactor Regulation i
Docket No. 50-333
Enclosure:
As stated ,
cc w/ encl: See next page ' l
. S. Bajwa -OGC.
PUBLIC 1 S. Little ACRS
' PDl-1 R/F J. Williams C. Hehl, Region i
~ W. Reckley -
1J. 'Zwolinski (A) ,'
DOCUMENT NAME:G:\FITZ\ REPORT.LTR - .
- See previous concurrence To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" j
= Copy with' attachment / enclosure ' "N" s' No copy ~ ?
0FFICE. POI: POI 1 - 'd, l E LAIPDI 1 M V' l' OtPDI 1 d 1 -l P0tiP0lll*3* lE l IIAME JWit Liens:LccM - SLittte F - SBajus J'% leeckley l DATE 06/ 24/98 [ 06/ 2af98= 06/ M f98
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06/19/98 06/ /98
- t Official Record Copy 98070102M 990626 5
- PDR ADOCK!05000333 P,. = , PDR_ .
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i L- , Mr. J:mes Knubel June 26, 1998 s Chief Nucle:r Officer Power Auth rity of ths Stata cf
, New Yod 123 Main Street White Plains, NY 10601 t
SUBJECT:
NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
Dear Mr. Knubel:
l The enclosed report provides the results of an audit conducted by the Office of Nuclear Reactor Regulation (NRR) of the commitment management program at the James A. FitzPatrick Nuclear Power Plant. The insights gained from the audit at this facility will be used, along with the results from similar audits of seven other licensees' commitment management programs, to determine i L what, if any, changes to NRC policy or regulations are warranted. In addition, the staff has undertaken discussions with the Nuclear Energy Institute (NEI) to determine if changes in their i
guidance document, " Guideline for Managing NRC Commitments," might be mutually beneficial '
l for licensees and the NRC staff. The staff's efforts and recommendations in this area will be l presented in reports to the Commission later this year. !
Overall, the FitzPatrick commitment management program was found to be adequate. The audit I found that commitment changes have been reported to NRC consistent with the NEl guidance. I Planned procedure revisions should improve documentation of the critical thought processes used to disposition an item. The audit n!so found that commitment closure documentation was adequate to determine basis for action.
We thank your licensing staff and other personnel who participated in the audit for their cooperation. If you have any questions or comments concoming this report or the related efforts to improve NRC and industry guidance in the area of commitment management, please contact Joe Williams at (301) 415-1470 or William Reckley at (301) 415-1314.
Sincerely, Original Signed by:
S. Singh Bajwa, Director Project Directorate 1-1
. Division of Reactor Projects - t/II Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosure:
As stated
- cc w/ encl: See next page DISTRIBUTION:
Docket File- S. Bajws OGC PUBLIC S. Little ACRS-PDI-1 R/F J. Williams C. Hehl, Regien I
'J. Zwolinski (A)- W. Reckley DOCUMENT NAME:G:\FITZ\ REPORT.LTR - "See previous concurrence To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "C a Copy with attachment / enclosure "N" = No copy twice m:mi t fL I e LA:pos t a i onmi-1 ,( 1 I m:Posii 3 Ie I ame atti : ice r # stitei. 7 se.N. pM wn.ett y DATE 06/24/96 / 06/ h /98- 06/ S r98 06/19/98 06/ /98 Officiel Record' Copy
. nog g y k* UNITED STATES g - NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 300eH001
\9,, g June 26, 1998 Mr. James Knubel Chief Nuclear Officer 4 Power Authority of the State of New York 123 Main Street
) White Plains, NY 10601
SUBJECT:
NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
Dear Mr. Knubel:
The enclosed report provides the results of an audit conducted by the Office of Nuclear Reactor !
Regulation (NRR) of the commitment management program at the James A. FitzPatrick Nuclear !
Power P! ant. The insights gained from the audit at this facility will be used, along with the results from similar audits of seven other licensees' commitment management programs, to determine 1 what, if any, changes to NRC policy or regulations are warranted in addition, the staff has undertaken discussions with the Nuclear Energy Institute (NEI) to determine if changes in their guidance document, " Guideline for Managing NRC Commitments," might be mutually beneficial ;
for licensees and the NRC staff. The staff's efforts and recommendations in this area will be presented in reports to the Commission later this year.
Overall, the FitzPatrick commitment management program was found to be adequate. The audit
. found that commitment changes have been reported to NRC consistent with the NEl guidance.
Planned procedure revisions should improve documentation of the critical thought processes used to disposition an item. The audit also found that commitment closure documentation was adequate to determine basis for action.
We thank your licensing staff and other personnel who participated in the audit for their cooperation. If you have any questions or comments concoming this report or the related efforts to improve NRC and industry guidance in the area of commitment management, please contact Joe Williams at (301) 415-1470 or William R.eckley at (301) 415-1314. -
Sincey S. Singh Bajwa, Director Project Directorate 1-1 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation Docket No. 50-333. ,
Enclosure:
As stated cc w/ encl: See next page 4
( .; .
James Knubel James A. FitzPatrick Nuclear Power Authority of the State Power Plant of New York cc:
Mr. Gerald C. Goldstein Regional Administrator, Region I Assistant General Counsel U.S. Nuclear Regulatory Commission Power Authority of the State 475 Allendale Road of New York King of Prussia, PA 19406 1633 Broadway New York, NY 10019 Mr. F. William Valentino, President New York State Energy, Research, Resident inspector's Office and Development Authority U. S. Nuclear Regulatory Commission Corporate Plaza West P.O. Box 136 286 Washington Avenue Extension Lycoming, NY 13093 Albany, NY 12203-6399 Mr. Hany P. Salmon, Jr. Mr. Richard L. Patch, Director -
l Vice President - Engineering Quality Assurance Power Authority of the State Power Authority of the State of New York _
of New York 123 Main Street 123 Main Street White Plains, NY 10601 White Plains, NY 10601 Ms. Charlene D. Faison Mr. Gerard Goering Director Nuclear Licensing 28112 Bayview Drive Power Authority of the State Red Wing, MN 55066 of New York 123 Main Street Mr. James Gagliardo White Plains, NY 10601 Safety Review Committee 708 Castlewood Avenue Supervisor Arlington, TX 76012 Town of Scriba Route 8, Box 382 Mr. ArthurZaremba Licensing Manager Oswego, NY 13126 James A. FitzPatrick Nuclear Power Plant Mr. Eugene W. Zeltmann P.O. Box 41 President and Chief Operating Lycoming, NY 13095 Officer Power Authority of the State Ms. Paul Eddy of New York New York State Dept. of 99 Washington Ave., Suite No. 2005 Public Service Albany, NY 12210-2820 3 Empire State Plaza,10th Floor Albany, NY 12223 Charles Donaldson, Esquira Assistant Attomey General New York Department of Law 120 Broadway New York, NY 10271 I
i L !
l.. ,
COMMITMENT MANAGEMENT AUDIT JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 l 1. INTRODUCTION l As part of the staffs ac'Jvities related to improving the management of licensing basis
- l. Infonnation, audits of commitment management programs have been performed at eight reactor i facilities. The audits assessed licensees' implementation of commitments made to the NRC staff and also assessed the long-term control of commitments as a follow-up to the issuance of l industry guidance for evaluating and reporting changes to commitments made to the NRC. The James A. FitzPatrick Nuclear Power Plant was selected as one of eight facilities whose '
l commitment management programs were audited by the staff.
l 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 means 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 docurr. ants, or docketed correspondence without formal regulatory controls). The findings from the audits will be used in the staffs development of ,
recommendations to the Commission r'egarding the need for further staff actions in the area of !
commitment management.
The audit was conducted by the Office of Nuclear Reactor Regulation Project Manager, Joseph F. Williams, at the FitzPatrick plant from May 11 - 14,1998. Review oflicensee procedures, selection of target commitments for detailed review, and report composition were performed at ;
NRC headquarters in Rockville, MD over the weeks before and after the site audit. 1 l
ll. VERIFICATION OF LICENSEE IMPLEMENTATION OF PAST COMMITMENTS The licensee provided the auditor with a summary of completed items from its Action items and Commitments (ACTS) database. This summary includes completed regulatory commitments,
- along with other action items the licensee selects for tracking. The auditor selected items from this list for detailed review, with emphasis on items judged to have regulatory and safety
- significance. These selections were reviewed in order to determine whether the licensee effectively implements those commitments made to the NRC during staff reviews related to licensing actions and licensing activities. The auditor's findings regarding the licenswe's actions related to the selected items are described below.
COMMITMENTS REGARDING GENERIC LETTER 94 '
The auditor reviewed several commitments and action items associated with the licensee's response to Generic Letter (GL) 94-02, "Long-Term Solutions and Upgrade of Interim Operating Recommendations for Thermal-Hydraulic Instabilities in Boiling Water Reactors." Review of <
completed items in the ACTS database revealed the following 5 items:
ACTS # Description 12983 Complete procedures and training for implementation of option 1-D of GL 94-02.
12985 Ensure stability monitor is in service in the control room prior to Cycle 13 startup.
12986 Inform NRC of completion of long-term stability commitments.
16464 Submit a description of the on-line stability monitor, i
16465 Submit proposed technical specification changes.
These commitments were described in Attachment 3 of a licensee letter dated September 9, !
1994 which provided the licensee's initial response to GL 94-02, and in Attachment IV of a
{
licensee letter dated June 29,1995. The results of the auditor's review of each of these items is l
given below. j ACTS 12983 - Completion of procedures and training Operating procedure changes were required in order to implement technical specification changes under license amendment 236, which was issued on October 30,1996. The licensee provided a summary of the procedure reviews conducted. This summary included a description of the procedure change, or a brief justification as to why a change was not required. The auditor found this summary provided an adequate basis for closure of this portion of the '
commitment. However, note that this assessment does not address the technical adequacy of .
the changes made. I The licensee provided an outage closeout checidist which documented completion of training for all personnel except for 10 listed individuals. The auditor reviewed training records which confirmed those 10 individuals received the training at'a later date.
ACTS 12985 - Ensure stability monitor is in service in the control room prior to Cycle 13 startup The thermal-hydraulic stability monitor was installed by two modifications. The first modification, M1-96-018 removed a 6-second time constant from the Flow-Biased Average Power Range
. Monitor (APRM) Neutron Flux Scram Logic. The second modification, M1-95-130, provided for an upgrade of the plant computer system, including installation of computer software for monitoring thermal-hydraulic stability. The auditor reviewed documentation for each modification to confirm completion of the required work.
ACTS 12986 - Inform NRC of completion of long-term stability commitments The licenses documented completion of its GL 94-02 commitments in a letter dated January 27, 1997. This letter addressed all GL 94-02 commitments discussed in this report. <
ACTS 16464 - Submit a description of the on-line stability monitor >
The licensee submitted a description of the on-line stability monitor on March 29,1996. The auditor did not 16cate any correspondence documenting NRC review of this description.
- ACTS 16465 - Submit proposed technical specification changes
l l
l .
The licensee submitted proposed TS changes on March 22,1996. These changes were approved by Amendment 236, issued on October 30,1996.
COMMITMENTS ASSOCIATED WITH GL 88-20 in response to GL 88-20, "In&idual Plant Examination for Severe Accident Vulnerabilities," the !
licensee completed a probabilistic risk assessment (PRA), which it submitted to the staff on September 13,1991, with supplemental information provided on May 23,1992 and September 1, 1992. The NRC staff evaluation of th!s submittal was forwarded to the licensee by letter dated May 9,1994.
The licensee's evaluation had identified a number of potential improvements to procedures or the facility which could improve the plant's ability to cope with severe accidents. Those items which required additional evaluation were tracked as commitments in ACTS. The items reviewed by the auditor are given below.
ACTS # Description 16693 Evaluate feasibility of increasing N2 supply pressure.
16694 Evaluate use of the fire protection system for containment heat removal.
16695 Evatuste providing a cross-tie between RHRSW trains.
16696 Evaluate providing a tap from the fire protection system to the 'B' RHRSW header.
16697 Evaluate protecting HPCI and RCIC control centers from spray and splashing.
19899 Update the FitzPatrici;iPE The results of the auditor's review of each of these items is given below.
ACTS 166931 Evaluate feasibility of increasing nitrogen supply pressure The licensee evaluated whether increasing the nitrogen supply pressure to control the safety relief valves would be beneficial during events that lead to high containment pressure. This item was closed by the licenss e via an intemal memorandum dated January 16,1993. The licensee concluded that the existing system provides for solenoid valve operation up to 125 psig.
Containment failure is projected at 140 psig. Therefore, the licensee determined that the proposed modification would be of limited benefit because of the small reduction of nsk.
ACTS 16694 - Evaluate use of the fire protection system for containment heat removal Licensee personnel avaluated whether the fire protection system could provide sufficient containment heat removalin the . event of a loss of RHRSW This analysis concluded that this use of the system was feasible, as documented in a licansee intemal memorandum dated June 17,1996. This memorandum documented closure of ACTS 16694. Four additional ACTS items (21568 - 21571) were opened to track implementation of this recommendation by operations and training personnel, and to ensure this change was reflected in the iPE update.
1 4
The auditor reviewed documentation to verify completion of relevant procedure changes,
' documentation of training, and incorporation of the change in the IPE update.
ACTS 16695 - Evaluate providing a cross-tie between RHRSW trains, and ACTS 16696 - Evaluate providing a tap from the fire protection system to the 'B' RHRSW header l
' These two items were closed with no action taken based on the results of the evaluation completed for ACTS 16694. The licensee concluded that these items were functionally equivalent to, but more costly than, the changes made as result of evaluations performed for
. ACTS 16694.
ACTS 16697 - Evaluate protecting HPCI and RCIC control centers from spray and splashing This item was closed'by the licensee via an intemal memorandum dated January 16,1996. The L licensee determined that the frequency of intemal flooding events that could result in splashing of the HPCI and RCIC motor control centers is small (less than 104/ year). The projected reduction ;
in core damage frequency was found to be insignificant when compared to industry guidelines.
ACTS 19899 - Update the FitzPatrick IPE Completion of this item is documented by an intemal licensee memorandum dated April 6,1998.
This memorandum summarized results of a revised PRA which included recent NRC insights, and modifications to plant design and procedures. The licensee estimated the mean core damage frequency (CDF)4as 2.44 x 10 / reactor year. This frequency is slightly greater than the IPE estimate of 1.92 x 10 / reactor year. The April 6,1998 memorandum provides a summary discussion of the model changes the licensee believes are responsible for the revised CDi'. The auditor concluded that this summary indicates the licensee conducted a thorough review and reanalysis to resolve this ACTS item. The auditor did not review any postion of the revised PRA to determine its technical adequacy.
OTHER COMMITMENTS The auditor reviewed closure documentation for several miscellaneous commitments.
ACTS 18156 - Criteria for determining suppression pool cleanliness, cleaning frequency, and sampling On November 16,1995, the licensee submitted its response to Bulletin 95-02, " Unexpected Clogging of Residual Heat Removal (RHR) Pump Strainer While Operating in Suppression Pool Cooling Mode." This response included a commitment to enhance the torus preservation prograrn to include criteria for determining the appropriate suppression pool cleaning frequency,-
measures for sampling suppression pool water, and criteria for evaluating the pool cleanliness.
The auditor reviewed a intomal licensee rnemorandum dated September 30,1996, PEP-JS-96 293, which documented the basis for closure of this ACTS item. The auditor noted
- that several additional ACTS items, (22405, 22708,22770, and 22772) which were opened to track long-term actions for torus cleaning and routine review of water samples by responsible personnel to ensure fibrous material content'is maintained at a very low level. The licensee also completed PEP-APL-95-017, Revision 4, " Action Plan for Torus Preservation," dated October 11,
1996, which documents development of requirements for future suppression pool inspections and maintenance of the torus interior.
ACTS 20289 - Relocate specifications and bases for crescent area ventilation to an Authority-l controlled procedure controlled by 10 CFR 50.59 This item pertains to actions taken to implement license amendment 231, which authorized removal of crescent area ventilation requirements from the technical specifications. The auditor reviewed procedure AP-01.04, " Tech Spec Related Requirements, Lists, and Tables," revision 15, dated March 10,1998. This procedure is where the relocated requirements reside. Section 8.3.3 of this procedure requires that an approved 10 CFR 50.59 safety evaluation be completed for procedure changes other than editorial or typographical changes. Furthermore, the crescent area ventilation requirements in Attachment 3 state that 10 CFR 50.59 applies to any future changes to those requirements.
ACTS 22818 - Evaluate supplementary communications systems for use if normal systems are not functioning This item was a commitment made as a corrective action for LER 96-010. The ACTS tracking
- form for this item states that the licensee plans to purchase and install a wireless communications system in late 1997 or early 1998. ACTS 22818 was closed on the basis of completion of the required evaluation. ACTS 24152 was opened to track installation of the new communications system. As of the time of this audit in May 1998, this system was planned for installation by the end of 1998. The auditor finds that while this schedule is longer than originally projected, the licensee has fulfilled its commitment to perform an evaluation of the need for supplementary communications.
Ill. LICENSEE PROGRAMS FOR MANAGING (CHANGING) COMMITMENTS The licensee has developed a corporate policy on commitments, which is described by Nuclear Administrative Policy (NuAP) 4.2. The current revision of this policy is dated March 31,1992.
This policy defines a commitment as:
...an actual or implied pledge to outside regulatory agencies and industry organizations requiring Authority action to meet or maintain the pledge related to the design, operation or maintenance of the nuclear facility. A commitment can be either programmatic, procedural or hardware oriented. Requirements mandating action are considered to be commitments.
This definition differs somewhat from the NEl guidance, which defines a regulatory commitment as:
...an explicit statement to take a specific action agreed to or volunteered by a licensee that has been submitted in writing on the docket to the Commission.
The NuAP 4.2 definition is amewhat broader than this definition, and is expected to include any commitment tha'i would be developed under the NEl definition.
NYPA relies upon procedure NLP-2, " Preparation, Review, and Control of Submittals to Nuclear Regulatory Commission," to ensure regulatory commitments are incorporated into the Action and
6-Commitment Tracking System or ACTS. Revision 3, dated August 22,~ 1997, is the current version of NLP-2.
Each of the licensee's nuclear reactor sites (JAF and Indian Point Unit 3) have developed site-
- specific procedures for tracking regulatoly commitments under ACTS. At JAF, ACTS is implemented by AP-03.08. The current version of this procedure is revision 11, dated March 19, 1998. This procedure requires that changes to NRC commitments be controlled by Licensing,
. with approval authority given to a Department Manager, General Manager, or Director.
ACTS tracks " action items" and " action commitments." An action item is defined as a specific
' task assignment to correct a deficiency or to improve human or equipment performance that has a due date for completion. An action commitment is defined as an agreement, normally with an
- extemal agency such as NRC, to complete a corrective action or make an improvement with a due date for completion. The scope of" action commitment" includes commitments as defined by.
NuAP 4.2.
.The licensee has stated that it applies the NEl guidance to commitment changes. For example,
- a letter dated December 30,1997 stated that NEl guidance was applied to assess commitment changes. However, at the time of this audit, the NEl guidance was not formally incorporated into the licensee's procedures. Licensing personnel stated that they apply the NEl guidance without this formal guidance. The auditor believes that applying the guidance without formal controls
. could lead to an inconsistent level of documentation of critical thinking for commitment changes.
However, the auditor did not identify any instance where the licensee failed to notify NRC of a commitment change per the NEl guidance.
On a weekly basis, licensing personnel review near-term commitments in a management meeting. The auditor attended a management meeting on May .13,1998 where the licensee '
' discussed two items which were scheduled to be complete within 10 days. This routine discussion of commitments is helpful to emphasize their importance and to ensure appropriate resources are being allocated for their completion.
Commitments which require procedure changes are controlled per AP-02.01, " Procedure Writing Manual." Section 8.3.23 of AP-02.01, revision 8, dated February 27,1998 provides requirements that commitments be documented withb a procedure. The commitment references were found to provide an adequate means for tracking those items as procedure changes are made.
' Revision 6 or the Modification Control Manual (MCM) 4, " Nuclear Safety and Environmental
. lmpact Screens and Nuclear Safety Evaluations," dated March 13,1998, provides controls to
- ensure commitments are reflected in plant design changes. Section 6.2.1.c requires that personnel preparing a nuclear safety evaluation address commitments in the evaluation. The auditor found that this requirement was added as part of revision 6. Previously, licensee personnel were expected to address commitments in safety evaluations, though that expectation was not a formal part of MCM-4. The revision to MCM-4 should help ensure consistency in content in addressing commitments for design changes. As discussed below, the auditor reviewed a sample of evaluations completed before and after the MCM-4 revision to assess the licensee's commitment verification in design documents.
The licensee has drafted an administrative procedure which will affect handling of licensing l commitments. This procedura formally incorporate the NEl commitment management guidance into the licensee's program, which should ensure consistency in documentation of critical thinking
l for commitment change evaluations. The procedure supports greater use of available software
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tools which are expected to improve worker access to cross-referenced materials so that l
thorough evaluations can be performed. The licensee expects that a similar procedure change i will first be implemented at its other nuclear site, Indian Point Unit 3 in June 1998.
Implementation at FitzPatrick is expected to follow in mid to late July 1998, providing an opportunity to incorporate lessons leamed from the initial Indian Point Unit 3 application.
IV. EVALUATION OF COMMITMENT CHANGES in order to verify that the licensee effectively controls changes to commitments made to the NRC, the auditor selected a sample of commitments that the licensee has revised. The auditor's l . evaluation of these changes is discussed below. '
i LICENSEE LETTER JPN:98-001. JANUARY 8.1998 ,
This letter discusses changes to commitments that predate the ACTS process, so there is not an .
' ACTS number assigned. i This proposed commitment change revises supplier evaluation requirements of the licensee's quality assurance program. Such changes are controlled by 10 CFR 50.54, Therefore, the licensee requested NRC approval of the change before its implementation. This request for approval is consistent with the NEl guidance. The NRC is currently reviewing the proposed change.
LICENSEE LETTER JAFP-97-0500. DECEMBER 30.1997 Amendment 148 was issued on December 26,1989 This amendment reflected deletion of the low pressure coolant injection system loop selection logic, and clarified usage of the terms
" demonstrate" and " verify" in the technical specifications. The licensee's December 30,1997 letter affected commitments regarding the latter portion of this amendment.
In a letter dated November 20,1989, the licensee had described criteria which would be used to 8
" verify" operability. The commitment change documented by the licensee's December 30,1997 letter states that the licensee's work control processes provide an adequate means for assessing
_whether the operability criteria are satisfied, and that those processes are adequate to ensure
~
the Limiting Condition for Operation log is accurately maintained. The auditor reviewed the safety evaluation issued by the NRC staff for Amendment 148, and finds that the revised commitment provides a level of control consistent with the expectations of that evaluation.
The licensee's December 30,1997 letter stated that the licenses had utilized the guidance of SECY-95-300, which includes the NEl commitment management guidance. The auditor noted that the licensee did not document its assessment of the commitment change beyond the information provideri in their letter. Thus, it was not easy to reproduce how the licensee applied relevant portions of the guidance. However, the licensee reported the commitment change to NRC regardless, so the exact application of the guidance is moot.
LICENSEE 1ETTER JPN-96-034. JULY 18.1996 In this letter, the licensee informed the NRC of a design change which altered a commitment made to resolve NUREG-0737 Item II.E.4.2. The licensee completed a design change under
10 CFR 50.59 to replace solenoid-operated valves with check valves on the mini-purge lines for the reactor recirculation pumps. These valves form the outboard containment isolation boundary for those lines. The licensee found that the change improved component performance and reliability. The NEl guidance indicates that commitments changed via 10 CFR 50.59 should be L reported to the NRC in accordance with the regulations (10 CFR 50.59(b)(2)). In this case, the licensee reported the change to NRC in both its annual summary report of changes for 1996
' (submitted on June 9,1997) and the July 18,1996 letter.
LICENSEE LETTER JPN-96-041. OCTOBER 10.1996 In th!s letter, the licensee informed the NRC of a revision to a commitment made in response to GL 88-14, " Instrument Air Supply Problems Affecting Safety-Related Equipment." The licensee replaced a commitment to comply with a maximum particle size limit of 3 microns, as specified in ANSI /lAS Standard 7.3 with two new commitments. The first new commitment stated that the !
licensee would comply with the 40 micron particle size limit specified in ISA-S7.0.01-1996, and j would provide additional filtration for equipment requiring a smaller particle size limit. The ,
second new commitment provides for corrective actions to restore air quality to within manufacturer's specifications if problems were found through testing. Two ACTS items,28757 and 28758 were opened to track these new commitments. Reporting these changes to NRC ensures the staff has accurate information available about the licensee's program to address GL 88-14, and so meets the intent of the NEl guidance.
LICENSEE LETTER JPN-97-013. MARCH 24.1997
'In this letter, the licensee informed the NRC of changes to core spray system intomals inspections performed as requested by Bulletin 80-13, " Cracking in Core Spray Spargers." The licenses stated that it intends to perform the inspections using the guidance of EPl TR-106740, ;
"BWR Vessel and Intemals Project [BWRVIP)- BWR Core Spray intomals Inspection and Flaw ..
Evaluation Guidelines (BWRVIP-18)." This report was submitted for NRC review by the BWRVIP.
. on July 26,1996. The licensee stated that it would incorporate necessary changes into its inspection program based on the NRC review and approval of the report. Reporting this change to NRC ensures the staff has accurate information available about the licensee's program to address Bulletin 80-13, and so meets the intent of the NEl guidance.
LER 93-009-03. FEBRUARY 22.1996 The licensee had committed to a corrective action in LER 93-009 (May 19,1993) to replace feedwater pump discharge check valves 34FWS-4A and 34FWS-48. The licensee replaced check valve 34FWS-4A'during the 1994 refueling outage. However, based on inspections of
. valve 34FWS-4B and subsequent reliable valve performance, the licensee revised its original commitment from valve replacement to performance monitoring, including inspection during each refueling outage. This commitment change.was reported to the NRC by LER 93-009-03 on February 22,1996.- Reporting this change to NRC ensures the staff has accurate information available about the licensee's response to problems identified in LER 93-009, and so meets the intent of the NEl guidance.
ACTS 02243'- Pioe Supports This ACTS item documents an open commitment made by the licensee in a letter date May 3, 1991, where the licensee committed to complete upgra6es of numerous pipe supports over the
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next several refueling outages. The upgrades were projected to be completed by the end of ,
refueling outage 15, which is presently scheduled for the Fall of 2002. The auditor selected this !
item because of the long schedule and large number of components (approximately 2400) I involved in order to assess whether the licensee was managing its activities in order to complete its commitment as planned. A failure to property manage the required modifications could result in a de facto commitment change.
1 At the time of this audit, the licensee has completed actions on about 1900 pipe supports, with a remaining work scope of 513 supports. The licensee has been conducting engineering and licensing reviews of the remaining scope in order to determine whether some scope reduction is practical. The licensee has determined that relief from ASME Code requirements may be required in some cases if the work scope is reduced. Such relief would require prior authorization by the NRC. The auditor concluded that the licensee has managed its actions in a manner which should make it practical to complete the commitment as scheduled, and that changes in the scope of the commitment will be appropriately communicated to NRC.
- 4. Traceability The auditor reviewed the licensee's processes for commitment traceability. The ACTS database, described above, provides tracking for all commitments, and includes a responsible individual and/or organization, and schedule tracking. This database is adequate to ensure all commitments are retrievable.
Commitments incorporated into procedures are explicitly referenced, as required by AP-02.01.
The auditor concluded that this level of control is adequate to ensure appropriate review of procedure changes for their impact on commitments, therefore, the auditor did not review any procedure changes as part of this assessment.
The most recent revision of MCM-4 requires a review of the licensing basis, including commitments, when assessing a design change. However, this requirement was only recently instituted. Therefore, the auditor selected 3 design changes described in the licensee's 1997 report of changes made under 10 CFR 50.5g which were completed under a previous MCM-4 revision in order to determine whether a licensing basis review was conducted. The changes reviewed were JAF-CE-94-108, " Fire Barrier Penetration Seals, Fire Dampers and Fire Doors, AP-01.04 Changes," JAF-SE-95-034, " Evaluation of Removal of Various Containment isolation Valves From AP-01.04," and JAF-SE-g7-039, " Torus /Drywell Vacuum Breaker Altemate Test
. Method." The auditor found that each of these evaluations included a licensing basis review.
These review were quite extensive in some cases. The auditor did not condtnt an independent assessment to determine whether these licensing basis reviews were comprehensive.
V. LICENSEE SELF-ASSESSMENTS The licensee has not completed any self-assessments of its commitment management program for FitzPatrick.
l VI. CONCLUSIONS /
SUMMARY
Overall, the FitzPatrick commitment management program was found to be adequate. The auditor found that the licensee's ACTS database provides an adequate means to track commdments made to the NRC. While the licensee's current commitment management program L_____-_____-__-__-_-_--_--_ _ - - - - _
i lacks rigorous documentation of application of NEl guidance, the auditor found that commitment changes have been reported to NRC consistent with that guidance. However, the program could be strengthened to improve documentation of the critical thought processes used to disposition an item. Upcoming procedure revisions should address this issue. The auditor also found that i commitment closure documentation was adequate to determine basis for action. l l
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