ML081230393

Audit of Licensee'S Regulatory Commitment Management Program for Audit Performed April 9-10, 2008

ML081230393
Person / Time
Site:	River Bend
Issue date:	05/08/2008
From:	Donohew J NRC/NRR/ADRO/DORL/LPLIV
To:	Entergy Operations
Donohew J N, NRR/DORL/LPL4, 415-1307
References
TAC MD7465
Download: ML081230393 (11)

Text

May 8, 2008 Vice President, Operations Entergy Operations, Inc.

River Bend Station 5485 U.S. Highway 61N St. Francisville, LA 70775

SUBJECT:

RIVER BEND STATION, UNIT 1 - AUDIT OF LICENSEES REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NO. MD7465)

Dear Mr. Venable:

The enclosed report provides the results of an audit conducted by U.S. Nuclear Regulatory Commission (NRC) staff on April 9 and 10, 2008, of the regulatory commitment management program at River Bend Station, Unit 1 (RBS). Based on the audit, the NRC staff concludes that (1) the licensee has implemented commitments made to the NRC on a timely basis, and (2) with some minor inconsistencies, RBS has implemented an effective program for managing NRC commitment changes.

Details of the audit are provided in the enclosed audit report, including our observations and recommendations.

Sincerely,

/RA/

Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-458

Enclosure:

Audit Report cc w/encl: See next page

ML081230393 OFFICE NRR/LPL4/PE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME IAnchondo JDonohew JBurkhardt THiltz DATE 5/5/08 5/5/08 5/5/08 5/8/08 River Bend Station (2/25/2008) cc:

Senior Vice President Attorney General Entergy Nuclear Operations State of Louisiana P.O. Box 31995 P.O. Box 94095 Jackson, MS 39286-1995 Baton Rouge, LA 70804-9095 Vice President, Oversight President of West Feliciana Entergy Nuclear Operations Police Jury P.O. Box 31995 P.O. Box 1921 Jackson, MS 39286-1995 St. Francisville, LA 70775 Senior Manager, Nuclear Safety Mr. Brian Almon

& Licensing Public Utility Commission Entergy Nuclear Operations William B. Travis Building P.O. Box 31995 P.O. Box 13326 Jackson, MS 39286-1995 1701 North Congress Avenue Austin, Texas 78701-3326 Senior Vice President

& Chief Operating Officer Mr. Jim Calloway Entergy Operations, Inc. Public Utility P.O. Box 31995 Commission of Texas Jackson, MS 39286-1995 1701 N. Congress Avenue Austin, TX 78711-3326 Associate General Counsel Entergy Nuclear Operations Ms. H. Anne Plettinger P.O. Box 31995 3456 Villa Rose Drive Jackson, MS 39286-1995 Baton Rouge, LA 70806 Manager, Licensing Mr. Richard Penrod, Senior Environmental Entergy Operations, Inc. Scientist/State Liaison Officer River Bend Station Office of Environmental Services 5485 US Highway 61N Northwestern State University St. Francisville, LA 70775 Russell Hall, Room 201 Natchitoches, LA 71497 Louisiana Dept. of Environmental Quality Radiological Emergency Planning and Senior Resident Inspector Response Division P.O. Box 1050 P.O. Box 4312 St. Francisville, LA 70775 Baton Rouge, LA 70821-4312 Regional Administrator, Region IV Louisiana Dept. of Environmental Quality U.S. Nuclear Regulatory Commission Office of Environmental Compliance 611 Ryan Plaza Drive, Suite 400 P.O. Box 4312 Arlington, TX 76011-8064 Baton Rouge, LA 70821-4312

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION RIVER BEND STATION, UNIT 1 DOCKET NO. 50-458

1.0 INTRODUCTION AND BACKGROUND

In SECY-00-045, Nuclear Energy Institute (NEI) 99-04, Guidelines for Managing NRC Commitments Changes, Revision 0, the Nuclear Regulatory Commission (NRC) staff informed the Commission that it had found NEI 99-04 contains acceptable guidance for controlling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors and the Commission endorsed NEI 99-04 (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 licensees 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. In accordance with NEI 99-04, the NRC is informed of any regulatory commitment change that has safety or regulatory significance.

On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR) issued Office Instruction LIC-105, AManaging Regulatory Commitments Made by Licensees to the NRC,@ Revision 0.

LIC-105 is consistent with NEI 99-04 guidance, and it further provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments. As stated in LIC-105, which cites the definition from NEI 99-04, a Aregulatory commitment@ is an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. LIC-105 further directs the NRR Project Manager (PM) to Aaudit 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 (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.).@ The audit is to be performed every 3 years.

2.0 AUDIT SCOPE AND RESULTS 2.1 Audit Scope An audit was performed at the River Bend Station, Unit 1 (RBS) site on April 9 and 10, 2008.

The NRC staff defined the period to be covered by this audit to be the time period from the last audit which was performed in July 2004. The completion of the previous audit is the audit report

dated January 6, 2005 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML043630190). The conclusions in the previous report were the following:

(1) the licensee has implemented NRC commitments on a timely basis, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.

The scope of the audit was limited to the commitments made in writing to the NRC as a result of past licensing actions/activities. In order to generate an adequate list of items prior to the audit, the NRC staff searched ADAMS for RBS licensing actions and licensing activity submittals issued in the past 3 to 4 years. Additionally, the licensee provided a list of regulatory commitments performed since the last audit report. The attached table lists the commitments selected for this audit.

The licensee provided the documentation necessary to support the NRC staffs audit in each of the samples selected. The documents included summary sheets providing the status of the commitment and the appropriate backup documentation, as needed (i.e., plant procedures, incoming/outgoing records, and/or other plant documentation).

2.2 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 those commitments made to the NRC as part of past licensing actions/activities. For commitments that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.

RBS commitments are tracked in accordance with Entergy Operations, Inc. (the licensee),

Nuclear Management Manual Procedure EN-LI-110, Revision 0, ACommitment Management Program." The licensee enters commitments made to the NRC using a commitment tracking database called Licensing Research System (LRS). According to the licensee, the majority of these commitments fall into the category of One-time Actions. One-time action commitments are loaded into the database, tracked to implementation, and remain in the database for historical reference. Since the system was created, the licensee has entered more than 12,000 licensee-defined commitments; of which at the time of the audit, 127 were designated as OPEN actions items.

The NRC staff reviewed documentation generated by the licensee categorized as Commitment Changes, Generic Letter responses, Relief Request, and Amendments, to assess the implementation of the licensee=s procedure EN-LI-110, including the status of their completion.

After review of the commitments selected for the audit, the NRC staff found that the licensee=s commitment tracking program had captured all of the regulatory commitments and that all of the commitments were met or were on schedule. However, the NRC staff noted that implementation of the program had some minor inconsistencies. These observations are described Section 2.4 of the report.

2.3 Verification of the Licensee=s Program for Managing NRC Commitment Changes This part of the audit is to assess the licensees performance related to implementing controls for modifying or deleting regulatory commitments made to the NRC. This ensures that changes to regulatory commitments are being evaluated in accordance with the licensees procedures,

focuses on the licensees technical evaluation to verify that changes to commitments are adequately justified, and asserts commitments safety and regulatory significance in accordance with NEI 99-04.

2.3.1 Change Control Procedure Verification Changes to a commitment are reviewed by Plant Licensing Management and by the organization that made the change to the commitment. Once a change occurs, the originating department should review the revision against the commitment report to determine if the change maintains satisfactory implementation of the commitment. Attachment 9.4, Commitment Change Evaluation Form (CCEF), of procedure EN-LI-110, is used to document the evaluation of commitment changes. The NRC staff found Attachment 9.4, CCEF, for handling commitment changes is consistent with the guidance in NEI 99-04.

2.3.2 Procedure Implementation Assessment The NRC staff reviewed documentation generated by the licensee categorized as a Commitment Change in order to assess the effectiveness and implementation of such changes.

The NRC staff found that, with a few minor inconsistencies to be discussed in Section 2.4 of this report, the licensee had properly addressed each regulatory commitment change selected for this audit and that the licensee had implemented an effective program to manage commitment changes.

2.3.2.1 Commitment Changes Reportable to the NRC The licensee indicated that it reports all commitment changes to the NRC; therefore, this section is not applicable.

2.3.2.2 Traceability of Commitments Although guidance in NEI-99-04 does not specifically address traceability of commitments; LIC-105 states, [t]he PM should confirm that the licensee has integrated the commitment management system with other line organization functions to ensure traceability of a regulatory commitment following its initial implementation. In licensees procedure EN-LI-110 Section 5.8, Implementing Changes to Documents that Contain Commitments, Subsection [6], the licensee provides instances when implementing document changes should be forwarded to Plant Licensing. Section 5.8[6] states, [t]he procedure implementing a commitment has undergone reformatting thereby relocating the section or paragraph that implements the commitment. The change originator should provide a marked-up commitment report showing the new or revised section(s) or paragraph(s).

When changing documents, the licensees procedure directs that licensee staff should review the document being changed against the commitment report. If ownership for implementing a commitment transfers from one department to another, the person who originates the transfer must obtain approval and acceptance of ownership with the new department. Based on input from responsible departments, plant licensing staff reviews and updates commitment implementation information and incorporates the data into the LRS database.

Based upon the licensee's implementation of the requirements of EN-LI-110, with the exception of a few minor inconsistencies, the NRC staff found that the licensee=s commitments were traceable.

2.4 Audit Observations and Suggestions As stated above, licensees procedure EN-LI-110 was found to be consistent with the NEI Guidance, NEI 99-04. However, the NRC staff has made the following observations during the audit and believes that implementation of suggestions would aid in eliminating inconsistencies with traceability.

The NRC staff noted during its review that in four of the commitments, the licensee cited the incorrect reference document in the LRS commitment summary sheet. In all four instances, the commitment was being implemented by one of the RBS procedures (i.e., MA-119, RP-503, and MLP-7500). The NRC staff reviewed each procedure and found that each commitment maintained satisfactory implementation, and that the inconsistencies surfaced when the procedure had gone through a revision where the change(s) was not being communicated back to plant licensing.

In one instance, a document was provided by licensee to show that a commitment had been implemented; however, this document was not being cited as a reference in the commitment tracking database. This was discussed with the licensee and the licensee corrected this inconsistency by adding a reference to this document to the database.

In another instance, a document was referenced in the commitment tracking database with respect to the implementation of a commitment; however, the document in fact did not address the implementation of that commitment. This particular document was reviewed by both the licensee and the NRC staff, and as a result, the referenced document was removed from the database by the licensee. Implementation of the commitment was still documented by the remaining cited references.

EN-LI-110 guidance directs the organization in charge of the procedural change to report back to licensing if the commitment is now being implemented by another section(s) or paragraph(s) of the procedure. The NRC staff believes that better practice of communication, between those organizations making procedural revisions and licensing, will facilitate in having a precise, up-to-date commitment tracking system.

In spite of these minor inconsistencies and omissions, the correct information was available within the same document or easily traceable. Additionally, the licensee staff promptly issued a condition report to raise awareness of the problem and corrected the commitments with the proper reference documentation.

3.0 CONCLUSION

Based on the audit, the NRC staff concludes that (1) RBS has implemented commitments to the NRC on a timely basis, and (2) with some minor inconsistencies, RBS has implemented an effective program for managing NRC commitment changes.

The audit results were discussed on April 10, 2008, with David Lorfing and William Fountain.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT D. Lorfing and W. Fountain Principal Contributor: I. Anchondo Date: May 8, 2008

AUDIT OF ENTERGY OPERATIONS, INC.

MANAGEMENT OF REGULATORY COMMITMENTS AT RIVER BEND STATION PERFORMED APRIL 9 AND APRIL 10, 2008 LIST OF COMMITMENTS INCLUDED IN THE AUDIT Commitment No. Category No. TAC No. Issue Date Description 1 Amendment A-16603 MC4582 08/25/2005 The bases will be revised to confirm CLOSED that the alternative MCPR [minimum critical power ratio] and LHGR [linear heat generation rate] operating limits are sufficient to mitigate pressurization transient effects and that the alternative limits restore the margin to the MCPR assumed in the safety analysis.

2 Generic Letter A-16617 MC5552 05/25/2005 Application for technical specification CLOSED (TS) improvement to eliminate requirements to provide monthly operating reports and occupational radiation exposure reports.

3 Amendment A-16652 MC6327 12/01/2005 Upgrade FBCHC [Fuel Building Cask CLOSED Handling Crane] quality classification to Quality Program Applicable by 3/31/2005.

4 *Request A-16747 MD0170 03/21/2006 If Entergy determines that bi-directional Relief OPEN testing is only possible during a refueling outage, Entergy will perform such testing during the fall 2007.

5 *Request A-16748 MD0170 03/21/2006 Entergy has identified 580 Class 1, 2, Relief CLOSED and 3 check valves that are currently required to be unidirectionally tested in accordance with the IST [inservice testing] plan. Of these, 339 are scheduled to be tested during outages.

Entergy will begin incorporating these 339 check valves into the appendix 11 conditioning monitoring program upon approval of this request. By completion of the spring 2006 refueling outage (RF-13), these valves will meet the appendix 11 or ISTC requirements for bi-directional testing.

6 Amendment P-16618 MC5423 07/18/2006 Entergy will appropriately include in this IMPLEMENTED program the backup battery charger (BYS-CHRG1D) function associated with supporting this proposed TS change.

ATTACHMENT

Commitment No. Category No. TAC No. Issue Date Description 7 Request P-16622 MC5363 02/01/2005 An explanation of when standby rescue Relief IMPLEMENTED through personnel will be required will be clearly MC5367 explained in Entergy procedures before use of the Mururoa suit.

8 Amendment P-16649 MC6327 12/01/2005 All Critical lifts of the MCP, MCO Lid, IMPLEMENTED HI-TRAC Top, and Pool Lids, containing nuclear fuel or ever nuclear fuel, will be made using the main hook.

9 Amendment P-16699 MC6327 12/01/2005 Continuing inspection is in accordance IMPLEMENTED with the RBS preventative maintenance program for slings and special lifting devices. This will be accomplished on a frequency in accordance with ASME

[American Society of Mechanical Engineers] B30.9 and ANSI [American National Standards Institute] N14.6 prior to first cask loading.

10 Amendment P-16701 MC6327 12/01/2005 Personnel performing the engagement IMPLEMENTED of redundant rigging (for fuel building cask handling crane dry spent fuel cask loading operations) will be trained to perform this evolution prior to first cask loading campaign.

11 Request P-16767 MD1746, 10/02/2006 The Mururoa V4F1 R suit will be Relief IMPLEMENTED MD1749 integrated into Entergy Operations, Inc.

through Respiratory program using the MD1756 information provided by the manufacturer.

12 Request P-16775 MD1736, 10/02/2006 Based on the NRCs approval of this Relief IMPLEMENTED MD1739 request, Entergy will account for dose through consistent with the guidance of the MD1745 standard as follows: the DDE [deep-dose equivalent] for each compartment will be determined from dosimeters worn at that location, when no dosimeter is worn at a particular compartment, the DDE will be determined from the dosimeter positioned where the exposure is judged to be similar. The assigned EDE [effective dose equivalent] will be the sum of each DDE.

13 Request P-16778 MD1746, 10/02/2006 Notify the manufacturer (as well as the Relief IMPLEMENTED MD1749 U.S. Nuclear Industry) of any defects through experienced during the use of the MD1756 Mururoa V4F1 R devices.

Commitment No. Category No. TAC No. Issue Date Description 14 Request P-19789 MD1821, 10/02/2006 (Mururoa) suits are used only in Relief IMPLEMENTED MD1824 atmospheres containing specific through contaminants in concentrations that are MD1831 not IDLH [immediate danger to life and health] as given in NIOSH [National Institute for Occupational Safety and Health] Concept for Industrial Power, Air-purifying Respiratory Standard, draft for comment, May 30, 2005) http://www.cdc.gov/niosh/npptl/standars dev.html, and have an oxygen content of at least 19.5 percent by volume.

• Commitment No. A-167[47-48] were implemented by Commitment No. A-16746.