ML072780003

Audit Report of Licensee Regulatory Commitment Management Program for Audit Performed August 20-21, 2007

ML072780003
Person / Time
Site:	Wolf Creek
Issue date:	10/31/2007
From:	Donohew J N NRC/NRR/ADRO/DORL/LPLIV
To:	Muench R A Wolf Creek
Donohew J N, NRR/DORL/LP4, 415-1307
References
TAC MD6619
Download: ML072780003 (16)

Text

October 31, 2007Mr. Rick A. MuenchPresident and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - AUDIT OF LICENSEE REGULATORYCOMMITMENT MANAGEMENT PROGRAM (TAC NO. MD6619)

Dear Mr. Muench:

An audit of the Wolf Creek Nuclear Operating Corporation (WCNOC) regulatory commitmentmanagement program was performed at the Wolf Creek Generating Station on August 20-21, 2007. Based on this audit, the NRC staff concludes that WCNOC has an adequate program to implement and manage regulatory commitments. Details of the audit are provided in the enclosed audit report, including our observations and recommendations.Sincerely,/RA/Jack Donohew, Senior Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-482

Enclosure:

Audit Report cc w/encl: See next page

ML072780003OFFICENRR/SNPBNRR/LPL4/PMNRR/LPL4/LANRR/LPL4/BCNAMEAHoffmanJDonohewJBurkhardtTHiltz DATE10/22/0710/24/0710/11/0710/31/07 February 2006Wolf Creek Generating Station cc:Jay Silberg, Esq.

Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW Washington, D.C. 20037Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011Senior Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 311 Burlington, KS 66839Chief Engineer, Utilities DivisionKansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027Office of the GovernorState of Kansas Topeka, KS 66612Attorney General120 S.W. 10 th Avenue, 2 nd FloorTopeka, KS 66612-1597County ClerkCoffey County Courthouse 110 South 6 th StreetBurlington, KS 66839Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366Vice President Operations/Plant ManagerWolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839Supervisor LicensingWolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839U.S. Nuclear Regulatory CommissionResident Inspectors Office/Callaway Plant

8201 NRC Road Steedman, MO 65077-1032 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATIONREGULATORY COMMITMENTS MADE BY THE LICENSEE TOTHE U.S. NUCLEAR REGULATORY COMMISSIONWOLF CREEK NUCLEAR OPERATING CORPORATIONWOLF CREEK GENERATING STATIONDOCKET NO. 50-48

21.0INTRODUCTION

AND BACKGROUNDIn SECY-00-045, "Acceptance of NEI [Nuclear Energy Institute] 99-04, 'Guidelines forManaging NRC Commitments,'" the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff informed the Commission that it found that industry guidance document NEI 99-04 contains acceptable guidance for controlling regulatory commitments made by commercial reactor licensees to the NRC and the Commission endorsed NEI 99-04. The guidance in NEI 99-04 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments, which are defined as "explicit statement[s] to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket tothe NRC."The NRC staff has agreed that NEI 99-04 provides acceptable guidance to licensees for thecontrol of regulatory commitments made to the NRC staff. See Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000. The commitments will be controlled in accordance with the licensee's Commitment Management Program (CMP) in accordance with NEI 99-04. Any change to the regulatory commitments is subject to licensee management approval and subject to the procedural controls established at the plant for commitment management in accordance with NEI 99-04, which include appropriate notification of the NRC.The NRC's Office of Nuclear Reactor Regulation (NRR) performs audits of regulatorycommitments made by commercial reactor licensees. An NRR project manager audits the licensee's CMP by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (e.g., amendments, relief requests, exemptions) and activities (e.g., bulletins, generic letters). An audit is to be performed every 3 years. 2.0 AUDIT PROCEDURE AND RESULTSAn audit of the Wolf Creek Nuclear Operating Corporation's (WCNOC's, the licensee's)program for managing regulatory commitments at the Wolf Creek Generating Station, the Commitment Management System (CMS), was performed at the plant site on August 20-21, 2007. Since no such audit was performed prior to this date, the NRC staff defined the period of this audit to encompass approximately 6 years prior to the date of the audit, twice the normal period of 3 years. 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 thosecommitments made to the NRC as part of past licensing activities, satisfying both the action committed to and the overall intent of the commitment.The NRC staff selected a sample of individual and unrelated regulatory commitments that wereapproved by the NRC to justify a licensing action or resolve a licensing activity. This sample emphasized regulatory commitments encompassing a variety of systems, a variety of engineering disciplines, and a variety of licensing actions.The NRC staff reviewed reports generated by the licensee's CMS along with other relevantdocumentation to evaluate the status of the completion of regulatory commitments. The results of this review are listed in the attached Table 1. The NRC staff found that the licensee's CMS had adequately incorporated and implemented all of the regulatory commitments that were selected by the NRC staff for this audit.2.2 Verification of Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensee's performance related to implementingcontrols for modifying or deleting regulatory commitments made to the NRC in order to ensure that changes to regulatory commitments are evaluated in accordance with the licensee's programs and procedures, that the licensee's technical evaluations adequately justify the change, and that the NRC is informed of regulatory commitment changes that have safety or regulatory significance in accordance with NEI 99-04.The licensee manages regulatory commitments using procedure AI 26D-001, "CommitmentManagement System." In accordance with this procedure, commitment changes are evaluated using procedure AI 26A-003, "Evaluation of Proposed Change (Other than [Part 50, Section 59 of Title 10 of the Code of Federal Regulations])" with the aid of the flowchart inATTACHMENT A to AI 26D-001. The NRC staff reviewed Revision 5 of these procedures and concluded that they are consistent with the guidance of NEI 99-04; that the procedures constitute adequate administrative controls for modifying and deleting regulatory commitments made to the NRC; that the programs provide guidance regarding the evaluation of proposed changes to regulatory commitments in terms of safety and regulatory significance; and that the guidance included criteria consistent with NEI 99-04 for determining when it would be appropriate to notify the NRC of a regulatory commitment change. The NRC staff selected a sample of regulatory commitment changes that were reported to theNRC. In addition, the licensee provided examples of regulatory commitment changes that the licensee has not and does not plan to report to the NRC. The samples of reported and non-reported regulatory commitments are listed in the attached Table 2. The NRC staff found that the licensee's CMS had adequately evaluated all of the regulatory commitments that were sampled and reported those changes to NRC that met the criteria in NEI 99-04.2.3 Additional Observations and Recommendations(a)The licensee explicitly identifies regulatory commitments in outgoingcorrespondence to the NRC and when such correspondence does not include any commitments, the licensee will include a statement to the effect, "There are no commitments associated with this submittal" in the cover letter. When such commitments are included in the letter, there is an attachment to the letter that clearly states that the attachment contains regulatory commitments, what these commitments are, and when the commitments will be implemented. These explicit statements that the correspondence contain or do not contain regulatory commitments represent clear and effective communications, and is considered by the NRC staff to be a positive initiative on the part of the licensee.(b)The licensee's commitment tracking software as a part of their documentmanagement system was a powerful tool that facilitated the straightforward location of not only information pertaining to the implementation and management of the commitment but also the location of related documents (e.g.,

the source document, procedures in which the commitment was implemented, reports documenting the implementation of the procedure). The licensee staff member assigned to support this audit had very little difficulty retrieving the required documentation.(c)Some sampled entries within the commitment tracking software had incorrect orabsent information (e.g., incorrect status, no closure date). In spite of these inconsistencies and omissions, the correct information was generally available elsewhere within the document management system.

3.0 CONCLUSION

Based on the above audit, the NRC staff concludes that (1) the licensee has an adequateprogram to implement and manage regulatory commitments, and (2) the licensee has an adequate program to implement and manage changes to regulatory commitments. 4.0 LICENSEE PERSONNEL CONTACTED AT SITE FOR THIS AUDITBill Muilenberg Attachments:1. Table 1: Implemented Regulatory Commitments

2. Table 2: Revised or Deleted Regulatory CommitmentsPrincipal Contributor: Adam Hoffman, NRR Date: October 31, 2007 AUDIT OF WOLF CREEK NUCLEAR OPERATING CORPORATION (WCNOC)MANAGEMENT OF REGULATORY COMMITMENTSAT WOLF CREEK NUCLEAR GENERATING STATIONPERFORMED AUGUST 20-21, 2007LIST OF COMMITMENTS INCLUDED IN AUDITTable 1. Implemented Regulatory CommitmentsItem No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure12001-02611/14/2001WCNOC will provide the requestedinformation (NRC Bulletin 2001-01, Request 5) or indicate no leakage was found, within 30 days after plant restart following the next refueling outage.

Closed5/22/2002During refueling outage 12, aremote visual inspection of the top of the reactor vessel head was performed to support an engineering evaluation of its condition. No evidence of leakage through reactor vessel penetrations or reactor vessel penetration nozzle cracking was found. These results were communicated by licensee submittal ET 02-0023 (Agencywide Documents Access and Management System Accession No.

ML021610273).

Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure 22002-02512/4/2002WCNOC will conduct a MRP inspectionplan "supplemental visual examination" in Refueling Outage #14, currently scheduled for spring 2005.

Closed(No date in CMS)This commitment wassuperseded by NRC Revised Order EA-03-009, Issuance of First Revised Order (EA-03-009) Establishing Interim Inspection Requirements For Reactor Pressure Vessel Heads at Pressurized Water Reactors.32003-0589/19/2003A surveillance procedure for inspectionof the lower RPV head will be developed and will include the following elements:

• Use of VT-2 examination techniques

• 100% circumferential examination of the all penetration tubing below the lower RPV head (58 total penetrations)

• 100% circumferential examination of the annulus region between the lower RPV head and the penetration tubing

• 100% examination of the lower head surface

• Requirements for pictorial documentation as well as written descriptions of all relevant Indications Closed12/12/2003The required elementsdeveloped for the lower head inspection are contained in a surveillance procedure.42003-0599/19/2003A bare-metal visual inspection of thelower RPV head will be performed.

Closed11/27/2003The appropriate surveillanceprocedure was performed.

Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure 52003-0609/19/2003WCNOC will submit to the NRC:* a summary of the inspections performed,

• the extent of the Inspections,

• the methods used,

• a description of the as-found condition of the lower head,

• any findings of relevant indications of through-wall leakage, and

• a summary of the disposition of any findings of boric acid deposits and any corrective actions taken as a result of indications found.

Closed(No date in CMS)The required information wasprovided in licensee submittal WM 04-0002.62003-06612/15/2003The proposed changes to the WCGSTechnical Specifications (Reactor Trip System Instrumentation and Engineered Safety Features Actuation System Instrumentation) will be implementedwithin 90 days of NRC approval.

Closed(No date in CMS)NRC issued Amendment No.156 on 1/31/2005.

Amendment No. 156 was implemented on 2/16/2005.72003-06712/15/2003Activities that degrade the availability ofthe auxiliary feedwater system, RCS pressure relief system (pressurizerPORVs and safety valves), AMSAC, or turbine trip should not be scheduled when a logic train or RTB train is inoperable for maintenance.

Closed(No date in CMS)These restrictions have beenimplemented in procedures.82003-06812/15/2003One complete ECCS train that can beactuated automatically must be maintained when a logic train is inoperable for maintenance.

Closed(No date in CMS)This restriction has beenimplemented in procedures.

Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure 92003-06912/15/2003Activities that cause master relays orslave relays in the available train to be unavailable and activities that cause analog channels to be unavailable should not be scheduled when a logic train or RTB train is inoperable for maintenance.

Closed(No date in CMS)These restrictions have beenimplemented in procedures.102003-07012/15/2003Activities on electrical systems (e.g., ACand DC power) and cooling systems (e.g., essential service water and component cooling water (CCW only for an inoperable logic train)) that support the systems or functions listed above should not be scheduled when a logic train or RTB train is inoperable for maintenance. That is, one complete train of a function that supports a complete train of a function noted above must be available.

Closed(No date in CMS)These restrictions have beenimplemented in procedures.112003-07112/15/2003The drift term used in the WCGSsetpoint study was originally based on a 30 day surveillance interval for COTs.

From historical experience, instrument drift is expected to remain within the assumptions of the existing setpoint study with the proposed change to a COT Frequency of 184 days. However, this expectation will be validated using future surveillance results subsequent to changing the COT Frequency to a 184 day interval.

Closed(No date in CMS)I&C is required to collect thisinformation with each surveillance. Trends are monitored and the results are provided to Safety Analysis.

Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure 122004-0807/23/2004The proposed changes to the WCGSTechnical Specifications (eliminating requirement for hydrogen recombiners and hydrogen monitors) will be implemented within 90 days of NRC approval. Revision to the TS Bases will be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment.

Closed(No date in

CMS, incorrectly listed as Open)The licensee implemented thechanges to the Technical Specifications and Technical Specification Bases.132004-0817/23/2004WCNOC has verified that a hydrogenmonitoring system capable of diagnosing beyond design-basis accidents is installed at WCGS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual. This regulatory commitment will be implemented within 90 days of NRC approval of this amendment request.

Closed(No date in

CMS, incorrectly listed as Open)Hydrogen monitors have beenincluded in the Technical Requirements Manual.142005-1077/31/2005Submit an update to informationcontained in WCNOC's response to Generic Letter 2004-02 Requested Information Item 2.

Closed5/31/2006The licensee submitted theinformation requested in letter WO 06-0028.152006-2379/27/2006WCNOC will notify the NRC ProjectManager for Wolf Creek Generating Station (WCGS) when the ultrasonic (UT) examination of the final full structural weld overlay is complete.

Closed11/06/2006The licensee notified theProject Manager (Jack Donohew) by email on 11/06/2006.

Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure 162006-2389/27/2006WCNOC will provide the results of theUT examinations of the full structural weld overlays of the WCGS Pressurizer safety, relief, spray and surge line nozzle welds to the NRC.

The results will include:

• A listing of indications detected;

• The disposition of all indications using the standards of ASME Section XI, Table IWB-3514-2 and/or Table IWB-3514-3; and, if possible,

• The type and nature of the indications Also included in the results will be a discussion of any repairs to the overlay material and/or base metal and the reason for the repair.

Closed11/17/2006The results of the UTexaminations were provided in letter ET 06-0055.17Not in CMS4/18/2005If cracking is found in the samplepopulation of bulges or overexpansions, the inspection scope will be increased to 100% of the bulges and overexpansions population for the region from the top of the hot leg tubesheet to 17 inches below the top of the tubesheet in the affected steam generator and 20% of the bulges and overexpansions population in the unaffected steam generators from the top of the hot leg tubesheet to 17 inches below the top of the tubesheet.

Closed(No date in CMS)The inspection was performedby Westinghouse Electric Corporation on 4/22/2005, the results of which were reported to the NRC in letter ET 06-0016.

Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure 18Not in CMS4/18/2005If cracking is reported at one or moretube locations not designated as either a top of the tubesheet expansion transition, a bulge or an overexpansion, an engineering evaluation will be performed. This evaluation will determine the cause for the signal, e.g.,

some other tube anomaly, in order to identify a critical area for the expansion of the inspection. This expanded inspection will be limited to the identified critical area within 17 inches from the top of the hot leg tubesheet.

Closed(No date in CMS)Since no cracking wasreported, no action was required to fulfill this commitment.19Not in CMS6/26/2006The license amendment (to removecontainment atmosphere gaseous radioactivity monitor from Technical Specification 3.14.15) will be implemented within 90 days of issuance.

Final TS Bases changes will be implemented pursuant to TS 5.5.14 at the time the amendment is implemented.

Closed(No date in CMS)The licensee implemented thechanges to the Technical Specifications and Technical Specification Bases. Table 2. Revised or Deleted Regulatory CommitmentsItem No.Commitment No.CommitmentChange DateDescription of CommitmentChange to CommitmentReportedto NRC?EvaluationConsistent with

Procedure?201997-1795/10/2006The Plant Manager willestablish a performance indicator on approved work hour deviations. This indicator is a tool for management monitoring of authorization frequency and justification.Work hour limitations willbe tracked in the cross functional team panels.

The Plant Manager will remain cognizant of any deviations through review of the division clock resets and related Condition Reports.YesYes211997-1815/10/2006Procedure AP 13-001,Revision 2, "Guidelines for WCGS Staff Working Hours,"

will be enhanced to provide better guidance.Procedure was changedto state that work hour limitations will be included in the cross functional team panels.YesYes221986-26512/10/2003Compliance withadministrative controls [for combustible materials] will be maintained by increased inspections by the station fire protection specialist.Commitment remarkswas edited to provide clarification of the implementation of the commitment.NoYes232003-0328/5/2004WCNOC will reviseadministrative controls for monitoring and evaluating the containment atmosphere to require initiation of corrective action documentation when

sample results indicate potential RCS leakage or changes to RCS leakage.Additional guidance isimplemented by a second procedure to provide specific visual inspection parameters, limits, and notes to define specific actions needed based on the

results.NoYes Item No.Commitment No.CommitmentChange DateDescription of CommitmentChange to CommitmentReportedto NRC?EvaluationConsistent with

Procedure? 24Not Assigned2/6/2004Following an unscheduledreactor shutdown, the Independent Safety Evaluation Group (ISEG) is responsible for performing an independent evaluation of the unscheduled reactor trip data package in the same manner as the Plant Safety Review Committee.Only the Plant SafetyReview Committee will review the post-trip review, in fulfillment of requirement 1.1 of Generic Letter 83-28, "Required Actions Based on Generic Implications of Salem ATWS Events."NoYes