ML080040182

Correction Letter Regarding Safety Evaluation for Audit of Licensee'S Management of Regulatory Commitments

ML080040182
Person / Time
Site:	Seabrook
Issue date:	02/01/2008
From:	Miller G E NRC/NRR/ADRO/DORL/LPLI-2
To:	St.Pierre G F Florida Power & Light Energy Seabrook
Miller G, NRR/DORL, 415-2481
References
TAC MD6615
Download: ML080040182 (5)

Text

February 1, 2008

Mr. Gene F. St. Pierre, Site Vice President c/o James M. Peschel Seabrook Station FPL Energy Seabrook, LLC.

P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - CORRECTION LETTER REGARDING SAFETY EVALUATION FOR AUDIT OF THE LICENSEE

=S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD6615)

Dear Mr. St. Pierre:

On December 21, 2007, the Nuclear Regulatory Commission (NRC) provided the results of an audit of FPL Energy Seabrook LLCs, commitment management program. This document is available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML073480410. The Audit was performed in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-105, AManaging Regulatory Commitments Made by Licensees to the NRC.

@ Subsequently, your staff noted that there was a paragraph included on the last page of the Safety Evaluation (SE) which was not applicable to Seabrook Station, Unit No. 1. The NRC staff reviewed the paragraph, and agrees that it was an inadvertent inclusion from a different commitment management audit. Accordingly, a revised page 3 of the SE is enclosed in this letter.

If you have any additional questions regarding this matter, I may be reached via telephone at (301) 415-2481.

Sincerely, /ra/

G. Edward Miller, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-443

Enclosure:

As stated cc w/encl: See next page Mr. Gene F. St. Pierre, Site Vice President c/o James M. Peschel Seabrook Station FPL Energy Seabrook, LLC.

P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT NO. 1 - CORRECTION LETTER REGARDING SAFETY EVALUATION FOR AUDIT OF THE LICENSEE

=S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD6615)

Dear Mr. St. Pierre:

On December 21, 2007, the Nuclear Regulatory Commission (NRC) provided the results of an audit of FPL Energy Seabrook LLCs, commitment management program. This document is available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML073480410. The Audit was performed in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-105, AManaging Regulatory Commitments Made by Licensees to the NRC.

@ Subsequently, your staff noted that there was a paragraph included on the last page of the Safety Evaluation (SE) which was not applicable to Seabrook Station, Unit No. 1. The NRC staff reviewed the paragraph, and agrees that it was an inadvertent inclusion from a different commitment management audit. Accordingly, a revised page 3 of the SE is enclosed in this letter.

If you have any additional questions regarding this matter, I may be reached via telephone at (301) 415-2481.

Sincerely, /ra/ G. Edward Miller, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-443

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

RidsAcrsAcnwMailCenter RidsNrrDorlLpl1-2 RidsOgcRp RidsNrrLAABaxter RidsNrrRgnIMailCenter RidsNrrPMGMiller PUBLIC LPLI-2 R/F ADAMS Accession Number: ML080040182 OFFICE LPLI-2/PM LPLI-2/LA LPLI-2/BC NAME GEMiller ABaxter HChernoff DATE 1/29/08 1/29/08 2/1/08 OFFICIAL RECORD COPY ENCLOSURE

Additionally, the annotations specifically refer to their related commitment allowing for enhanced traceability.

2.2 Verification

of the Licensee

=s Program for Managing NRC Commitment Changes The NRC staff reviewed the FPLE

=s procedure for regulatory commitment management with regard to managing a change or deviation from a previously-completed commitment. Generally, the procedure is consistent with the guidance of NEI-99-04 and it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments.

In Section 1.4 of the procedure, it states that the Regulatory Compliance Supervisor has responsibility for identification of new regulatory commitm ents contained in regulatory correspondence (incoming and outgoing). Additionally, the Regulatory Compliance Supervisor is tasked with maintenance and review of the database. Approval by Executive Management at, or above, the Director level is required for making regulatory commitments.

As set forth in Section 2.1 of this Safety Evaluation, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of this review of the licensee

=s information, as well as information from other sources, the NRC staff found no reason to differ from the licensee

=s reported status of the audited commitments. Therefore, the NRC staff surmises that the procedures used by the licensee to manage commitments are appropriate and effective.

3.0 CONCLUSION

The NRC staff concludes that, based on the above audit, (1) the licensee had implemented or is tracking for future implementation regulatory commitments; and (2) the licensee had implemented an effective program to manage regulatory commitment changes.

4.0 LICENSEE

PERSONNEL CONTACTED FOR THIS AUDIT

Michael O'Keefe Gary Kilby

Principal Contributor: G. E. Miller Seabrook Station, Unit No. 1

cc:

Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Mr. Peter Brann Assistant Attorney General State House, Station #6 Augusta, ME 04333

Resident Inspector U.S. Nuclear Regulatory Commission Seabrook Nuclear Power Station P.O. Box 1149 Seabrook, NH 03874

Town of Exeter 10 Front Street Exeter, NH 03823

Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Office of the Attorney General One Ashburton Place, 20th Floor Boston, MA 02108

Board of Selectmen Town of Amesbury Town Hall Amesbury, MA 01913

Mr. Robert Poole Federal Emergency Management Agency Region I 99 High Street, 6 th Floor Boston, MA 02110

Mr. Tom Crimmins Polestar Applied Technology One First Street, Suite 4 Los Altos, CA 94019

John Giarrusso Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

Ms. Kelly Ayotte, Attorney General Mr. Orvil Fitch, Deputy Attorney General 33 Capitol Street Concord, NH 03301

Mr. Christopher M. Pope, Director Homeland Security & Emergency Mgmt.

New Hampshire Department of Safety Bureau of Emergency Management 33 Hazen Drive Concord, NH 03301

Mr. M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Mr. Rajiv S. Kundalkar Vice President - Nuclear Technical Services Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

James M. Peschel Regulatory Programs Manager FPL Energy Seabrook, LLC PO Box 300 Seabrook, NH 03874

Ms. Marjan Mashhadi Senior Attorney Florida Power & Light Company 801 Pennsylvania Ave., NW Suite 220 Washington, DC 20004

Seabrook Station, Unit No. 1

cc:

Mr. Mark E. Warner Vice President, Nuclear Operations, North Region (Seabrook & Duane Arnold Plants)

Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420

Mr. Joseph Roy Director of Operations Massachusetts Municipal Wholesale Electric Company Moody Street Ludlow, MA 01056

Mr. Don E. Grissette Vice President, Nuclear Training and Performance Improvement Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 3340

Mr. Michael W. Kiley Plant General Manager FPL Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874