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{{Adams
#REDIRECT [[NRC 2006-0080, Response to Apparent Violation in Inspection Report 05000266/2006011; 0500301/2006011; EA-06-274]]
| number = ML063550037
| issue date = 12/19/2006
| title = Response to Apparent Violation in Inspection Report 05000266/2006011; 0500301/2006011; EA-06-274
| author name = Koehl D L
| author affiliation = Nuclear Management Co, LLC
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/RGN-III
| docket = 05000266, 05000301
| license number = DPR-024, DPR-027
| contact person =
| case reference number = EA-06-274, NRC 2006-0080
| document type = Letter, Licensee Response to Notice of Violation
| page count = 7
}}
See also: [[followed by::IR 05000266/2006011]]
 
=Text=
{{#Wiki_filter:Point Beach Nuclear Plant Committed
to Nuclear Excellence
Operated by Nuclear Management
Company, LLC December 19,2006 NRC 2006-0080  
10 CFR 2.201 U.S. Nuclear Regulatory
Commission
ATTN: Document Control Desk Washington, DC 20555-0001
Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Response to an Apparent Violation  
in Inspection  
Report 05000266/2006011~
0500301 /2006011;
EA-06-274
Reference:
(1) Letter from NRC to NMC dated November 21, 2006 As a result of inspections
conducted
by the U. S. Nuclear Regulatory
Commission (NRC) between April 1, 2006, and October 27, 2006, an Apparent Violation
of NRC requirements
contained
in 10 CFR 50.71 (e) and a non-cited
violation
were documented
in Reference
(1). The Apparent Violation
states that the Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR) was not updated in 1983 with the results of a reactor vessel head (RVH) drop analysis conducted
in 1982. It further states that in response to NRC questions
in 2005, Nuclear Management
Company LLC (NMC) made the determination
that amendments
to the PBNP Operating
Licenses were necessary
prior to updating the FSAR with this analysis, and furthermore, that administrative
controls for the movement of the PBNP RVHs were needed. These amendments
and administrative
controls were not in place for RVH moves from 1983 through 2004. Pursuant to the provisions
of 10 CFR 2.201, Nuclear Management
Company, LLC is responding
to the Apparent Violation
in the enclosure
to this letter. NMC concurs that the Apparent Violation
has been properly characterized
as a violation
of the requirements
of 10 CFR 50.71 (e). 6610 Nu~lear Road Two Rivers, Wisconsin
54241-9516
Telephone:
920.755.2321 
Document Control Desk Page 2 Summary of Regulatory
Commitments
This letter contains no new commitments
and no revisions
to existing commitments:
Dennis L. Koehl / Site Vice-President, Point Beach Nuclear Plant Nuclear Management
Company, LLC Enclosure
cc: Administrator, Region Ill, USNRC Enforcement
Officer, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC 
ENCLOSURE
Response to an Apparent Violation
in lnspection
Report 050002661200601
1 ; 0500301/2006011;  
EA-06-274  
Pursuant to the provisions
of 10 CFR 2.201, the following
is the NMC response to an Apparent Violation (EA-06-274)
of NRC requirements
as documented
in NRC lnspection
Report 05000266/2006011;
0500301/200601
dated November 21,2006. APPARENT VIOLATION
Contrary to the requirements
of 10 CFR 50.71 (e), the Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR)
was not updated in 1983 with the results of a reactor vessel head (RVH) drop analysis conducted
in 1982. Evaluation
of this analysis by Nuclear Management
Company, LLC (NMC) in 2005, in response to questions
from the NRC, resulted in NMC's determination
that amendments
to the PBNP Operating
Licenses were necessary
prior to updating the FSAR with this analysis.
This evaluation
also concluded
that the establishment
of administrative
controls on the movement of the PBNP reactor vessel heads (RVHs) was required.
The amendments
and administrative
controls were not in place for RVH moves from 1983 through 2004. NMC RESPONSE NMC concurs that the failure to update the FSAR in accordance
with the requirements
of 10 CFR 50.71 (e) was a violation
of NRC requirements.
Reasons for Violation:
There have been several evaluations
performed
to determine
the reasons for this Apparent Violation.
A description
of each of these evaluations
and its conclusions
is provided below. 1. Root Cause Evaluation (RCE) 277, Reactor Vessel Head Drop Analysis RCE 277, Reactor Vessel Head Drop Analysis, was performed
to identify the historical
and present-day
issues relating to the absence of a design basis or licensing
basis analysis of record for a reactor vessel head (RVH) drop accident.
Page 1 of 5 
2. RCE 300, Personnel
Awareness
and Understandina
of Licensina
Bases RCE 300, Personnel
Awareness
& Understanding
of Licensing
Bases, was chartered
in early December 2005, as a result of a streaming
analysis pelformed
by the PBNP senior management
team in late November 2005. RCE 300, Revision 1, was issued on April 27, 2006. The purpose of this RCE was to determine
the root and contributing
causes for the limited awareness
and inadequate
understanding
of regulatory
commitments
and requirements, including
legacy issues, such that docketed correspondence
has not always been incorporated
into licensing
basis documents, such as the FSAR. Additionally, the RCE evaluated
why regulatory
commitments
contained
in the correspondence
have not always been adequately
translated
into license basis implementing
documents
such as procedures.
3. PBSA-ENG-05-04, 10 CFR 50.59 Focused Self-Assessment
and Common Factors Assessment
A focused self-assessment
of implementation
of the 10 CFR 50.59 process at PBNP was conducted
on October 10-28,2005.
The purpose of the self-assessment
was to prepare for the baseline inspection
in December 2005, as well as to evaluate the effectiveness
of training conducted
in August 2005. One result of the self-assessment
was completion
of a common factors analysis (CFA) in order to determine
why some previous corrective
actions had not been effective.
The Common Factors Assessment (CFA) was conducted
during February 2006. 4. Common Cause Evaluation (CCE) of Component
Desiqn Basis Inspection (CDBI) Corrective
Action Documents
The purpose of this CCE was to obtain additional
insights into PBNP design and licensing
basis issues. The CCE confirmed
the conclusions
of RCE 300 with respect to its finding that design and licensing
basis information
is fragmented
and that additional
attention
should be placed on the preparation, review and approval of procedures
that implement
design requirements
to ensure these requirements
are appropriately
mapped. The reasons for the Apparent Violation
are: Activities
associated
with the design and licensing
basis were not elevated to a level of importance
such that the processes
and procedures
produce predictable
successful
outcomes.
The NMC RVH replacement
team failed to provide requested
information
on the RVH analysis to the vendor. Personnel
did not understand
the hierarchy
of the plant's licensing
and design bases within the regulatory
framework
of Title 10, Code of Federal Regulations.
Page 2 of 5 
The processes
intended to implement
the regulations
were fragmented
and insufficient
to ensure that design and license basis requirements
were properly mapped into their respective
implementing
documents.
In the case of the reactor vessel head replacement
project, there were no internal processes
and procedures
to effectively
govern conduct of the project. Clear ownership, roles and responsibilities
associated
with license basis maintenance
and control were not clearly defined. Corrective
Steps Taken and Results Achieved:
Corrective
steps were taken to address issues specific to the RVH drop analysis and the non-cited
violation
of 10 CFR 50.59. These corrective
steps are summarized
as follows: 1. On April 16, 2005, commitments
were made by NMC to NRC that provided compensatory
measures to enable movement of the original RVH. These commitments
were formalized
via letter NRC 2005-0050A
dated April 20, 2005, and subsequently
implemented.
2. On April 29, 2005, an application
for a proposed amendment
was submitted
to the Commission
via letter NRC 2005-055.
This application
was supplemented
by letters dated May 13, May 19, June 1, June4, June 9, June 20, and June 23,2005. 3. On June 24, 2005, NMC issued TRM 3.9.4, Reactor Vessel Head Lift, which provides required administrative
controls during lifting of a RVH over a reactor containing
fuel assemblies.
At the time of issue, TRM 3.9.4 was applicable
only to Unit 2. 4. On July 24, 2005, NMC requested
a similar amendment
for Unit 1 via letter NRC 2005-0094.
5. On August 15, 2005, the Unit 2 RVH drop analysis was incorporated
into the FSAR and submitted
to the NRC via the periodic FSAR update as required by 10 CFR 50.71 (e). 6. On September
23, 2005, TRM 3.9.4 was revised to reflect provisions
of the NRC Safety Evaluation
which delineated
administrative
controls during lifting of a RVH over a reactor containing
fuel assemblies.
This revision of TRM 3.9.4, therefore, applied to both PBNP units. 7. On August 15,2006, the PBNP FSAR was revised and submitted
to the NRC during the periodic update of the FSAR as required by 10 CFR 50.71 (e) to reflect applicability
for both units. Page 3 of 5 
8. Affected plant implementing
documents
such as Safe Load Path guidance for movement of heavy loads, RVH routine maintenance
procedures
used during each refueling
outage, Operations
containment
closure checklists
and refueling-related
procedures, etc., have been revised. 9. The NMC Project Management
Manual has been implemented
at PBNP. 10. A current licensing
basis (CLB) policy was developed
and issued on June 20, 2006. The policy defines and describes
the CLB; establishes
ownership
of CLB documents;
defines personnel
roles and responsibilities
for implementing
and maintaining
the CLB; establishes
expectations
for use and adherence
to the CLB; and describes
available
tools and methods for searching
the CLB. 11. A training needs assessment
for the CLB policy was completed
and concluded
that informational
sharing and/or formal training sessions were required for appropriate
station personnel.
Lesson plans have been developed
and approved.
Engineering, Regulatory
Affairs and 10 CFR 50.59 screening
and evaluation-qualified
personnel
received training during August 2006. 12. Corrective
actions identified
in the December 2005 10 CFR 50.59 self-assessment
were incorporated
into the Engineering
Continuing
Training Program. The revised training was provided to engineering
in August 2006. 13. A continuing
training module was developed
and conducted
with engineering
personnel
to develop a common understanding
of the definition
and vision of technical
rigor and to provide personnel
with an awareness
of the available
human performance
tools to improve technical
rigor. Training was completed
in December 2006. 14. The licensee response to the October 9, 1996, NRC "Request for lnformation
Pursuant to 10 CFR 50.54(f) Regarding
Adequacy and Availability
of Design Basis Information," was reviewed.
A validation
package was compiled supporting
the licensee response dated February 6, 1997. Following
this effort, a "living validation
package" was compiled which reflected
the 2006 status of statements
of fact contained
in the response.
15. A procedures
writerlreviewer
certification
matrix, along with a Job Familiarization
Guide (JFG), was developed
and is being implemented.
In addition, as part of this certification
process, information
sharing sessions are being conducted
to provide personnel
involved in procedure
writing and reviewing
with "hands-on" practical
experience
in searching
the site's Regulatory
lnformation
System, which includes the Regulatory
Commitment
Database.
16. Ownership
of the FSAR was transferred
from Engineering
to Regulatory
Affairs on December 15,2006. Page 4 of 5 
Corrective
Steps To Be Taken: There are no additional
corrective
actions required to address this violation.
Date Full Compliance
Will Be Achieved:
Full compliance
with NRC requirements
was achieved on August 15, 2006, for both units when the vessel head drop analysis for Unit 1 was incorporated
into the FSAR. Page 5 of 5
}}

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