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| number = ML072780003
| number = ML072780003
| issue date = 10/31/2007
| issue date = 10/31/2007
| title = Wolf Creek Generating Station - Audit Report of Licensee Regulatory Commitment Management Program for Audit Performed August 20-21, 2007
| title = Audit Report of Licensee Regulatory Commitment Management Program for Audit Performed August 20-21, 2007
| author name = Donohew J N
| author name = Donohew J
| author affiliation = NRC/NRR/ADRO/DORL/LPLIV
| author affiliation = NRC/NRR/ADRO/DORL/LPLIV
| addressee name = Muench R A
| addressee name = Muench R
| addressee affiliation = Wolf Creek Nuclear Operating Corp
| addressee affiliation = Wolf Creek Nuclear Operating Corp
| docket = 05000482
| docket = 05000482
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:October 31, 2007Mr. Rick A. MuenchPresident and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839
{{#Wiki_filter:October 31, 2007 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839


==SUBJECT:==
==SUBJECT:==
WOLF CREEK GENERATING STATION - AUDIT OF LICENSEE REGULATORYCOMMITMENT MANAGEMENT PROGRAM (TAC NO. MD6619)
WOLF CREEK GENERATING STATION - AUDIT OF LICENSEE REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NO. MD6619)


==Dear Mr. Muench:==
==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
An audit of the Wolf Creek Nuclear Operating Corporation (WCNOC) regulatory commitment management 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 Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482


==Enclosure:==
==Enclosure:==
Audit Report cc w/encl: See next page  
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.
ML072780003 OFFICE      NRR/SNPB            NRR/LPL4/PM          NRR/LPL4/LA        NRR/LPL4/BC NAME        AHoffman            JDonohew            JBurkhardt          THiltz DATE        10/22/07            10/24/07            10/11/07            10/31/07 Wolf Creek Generating Station cc:
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
Jay Silberg, Esq.                   Chief, Radiation and Asbestos Control Pillsbury Winthrop Shaw Pittman LLP Section 2300 N Street, NW                   Kansas Department of Health Washington, D.C. 20037              and Environment Bureau of Air and Radiation Regional Administrator, Region IV  1000 SW Jackson, Suite 310 U.S. Nuclear Regulatory Commission Topeka, KS 66612-1366 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011                Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corporation Senior Resident Inspector          P.O. Box 411 U.S. Nuclear Regulatory Commission Burlington, KS 66839 P.O. Box 311 Burlington, KS 66839                Supervisor Licensing Wolf Creek Nuclear Operating Corporation Chief Engineer, Utilities Division  P.O. Box 411 Kansas Corporation Commission       Burlington, KS 66839 1500 SW Arrowhead Road Topeka, KS 66604-4027              U.S. Nuclear Regulatory Commission Resident Inspectors Office/Callaway Plant Office of the Governor              8201 NRC Road State of Kansas                     Steedman, MO 65077-1032 Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839 February 2006


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
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482


==21.0INTRODUCTION==
==1.0    INTRODUCTION AND BACKGROUND==
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==
In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing 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 to the NRC.
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
The NRC staff has agreed that NEI 99-04 provides acceptable guidance to licensees for the control 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.
: 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.
The NRC's Office of Nuclear Reactor Regulation (NRR) performs audits of regulatory commitments made by commercial reactor licensees. An NRR project manager audits the licensees CMP by assessing the adequacy of the licensees 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.
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).
2.0      AUDIT PROCEDURE AND RESULTS An audit of the Wolf Creek Nuclear Operating Corporations (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.
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.
2.1      Verification of Licensees 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 activities, satisfying both the action committed to and the overall intent of the commitment.
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:
The NRC staff selected a sample of individual and unrelated regulatory commitments that were approved 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.
* Use of VT-2 examination techniques
The NRC staff reviewed reports generated by the licensees CMS along with other relevant documentation 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 licensees 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 Licensees Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensees performance related to implementing controls 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 licensees programs and procedures, that the licensees 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, Commitment Management 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 in ATTACHMENT 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 the NRC. 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 licensees 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 outgoing correspondence 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 licensees commitment tracking software as a part of their document management 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 or absent 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 adequate program 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 AUDIT Bill Muilenberg Attachments:
: 1. Table 1: Implemented Regulatory Commitments
: 2. Table 2: Revised or Deleted Regulatory Commitments Principal Contributor: Adam Hoffman, NRR Date: October 31, 2007
 
AUDIT OF WOLF CREEK NUCLEAR OPERATING CORPORATION (WCNOC)
MANAGEMENT OF REGULATORY COMMITMENTS AT WOLF CREEK NUCLEAR GENERATING STATION PERFORMED AUGUST 20-21, 2007 LIST OF COMMITMENTS INCLUDED IN AUDIT Table 1. Implemented Regulatory Commitments Item Commitment Commitment Description of Commitment                    Status    Method of Closure No. No.       Date 1    2001-026  11/14/2001    WCNOC will provide the requested          Closed    During refueling outage 12, a information (NRC Bulletin 2001-01,       5/22/2002 remote visual inspection of the Request 5) or indicate no leakage was               top of the reactor vessel head found, within 30 days after plant restart           was performed to support an following the next refueling outage.               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).
Attachment 1
 
Item Commitment Commitment Description of Commitment                  Status      Method of Closure No. No.       Date 2    2002-025  12/4/2002  WCNOC will conduct a MRP inspection        Closed      This commitment was plan supplemental visual examination     (No date in superseded by NRC Revised in Refueling Outage #14, currently         CMS)       Order EA-03-009, Issuance of scheduled for spring 2005.                            First Revised Order (EA-03-009) Establishing Interim Inspection Requirements For Reactor Pressure Vessel Heads at Pressurized Water Reactors.
3    2003-058  9/19/2003  A surveillance procedure for inspection    Closed      The required elements of the lower RPV head will be developed   12/12/2003  developed for the lower head and will include the following elements:               inspection are contained in a
* Use of VT-2 examination techniques                   surveillance procedure.
* 100% circumferential examination of the all penetration tubing below the lower RPV head (58 total penetrations)
* 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% circumferential examination of the annulus region between the lower RPV head and the penetration tubing
* 100% examination of the lower head surface
* 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.
* Requirements for pictorial documentation as well as written descriptions of all relevant Indications 4    2003-059  9/19/2003  A bare-metal visual inspection of the      Closed      The appropriate surveillance lower RPV head will be performed.         11/27/2003  procedure was performed.
Closed11/27/2003The appropriate surveillanceprocedure was performed.
Item Commitment Commitment Description of Commitment                  Status      Method of Closure No. No.       Date 5    2003-060  9/19/2003  WCNOC will submit to the NRC:               Closed      The required information was
Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure 52003-0609/19/2003WCNOC will submit to the NRC:* a summary of the inspections performed,
* a summary of the inspections             (No date in provided in licensee submittal performed,                                 CMS)        WM 04-0002.
* the extent of the Inspections,
* the extent of the Inspections,
* the methods used,
* the methods used,
Line 58: Line 83:
* any findings of relevant indications of through-wall leakage, and
* 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.
* 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.
6    2003-066  12/15/2003 The proposed changes to the WCGS            Closed      NRC issued Amendment No.
Closed(No date in CMS)NRC issued Amendment No.156 on 1/31/2005.
Technical Specifications (Reactor Trip     (No date in 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.
System Instrumentation and Engineered      CMS)        Amendment No. 156 was Safety Features Actuation System                        implemented on 2/16/2005.
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.
Instrumentation) will be implemented within 90 days of NRC approval.
Closed(No date in CMS)This restriction has beenimplemented in procedures.
7    2003-067  12/15/2003 Activities that degrade the availability of Closed      These restrictions have been the auxiliary feedwater system, RCS         (No date in implemented 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.
pressure relief system (pressurizer        CMS)
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.
PORVs 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.112003-07112/15/2003The drift term used in the WCGSsetpoint study was originally based on a 30 day surveillance interval for COTs.
8    2003-068  12/15/2003 One complete ECCS train that can be        Closed      This restriction has been actuated automatically must be             (No date in implemented in procedures.
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.
maintained when a logic train is           CMS) inoperable for maintenance.
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 Commitment Commitment Description of Commitment                  Status      Method of Closure No. No.       Date 9    2003-069  12/15/2003 Activities that cause master relays or    Closed      These restrictions have been slave relays in the available train to be (No date in implemented in procedures.
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.
unavailable and activities that cause     CMS) analog channels to be unavailable should not be scheduled when a logic train or RTB train is inoperable for maintenance.
Closed(No date in
10  2003-070  12/15/2003 Activities on electrical systems (e.g., AC Closed      These restrictions have been and DC power) and cooling systems         (No date in implemented in procedures.
: 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.
(e.g., essential service water and         CMS) 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
11  2003-071  12/15/2003 The drift term used in the WCGS            Closed      I&C is required to collect this setpoint study was originally based on a   (No date in information with each 30 day surveillance interval for COTs. CMS)        surveillance. Trends are From historical experience, instrument                 monitored and the results are drift is expected to remain within the                 provided to Safety Analysis.
: 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.
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.
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.
Item Commitment Commitment Description of Commitment              Status      Method of Closure No. No.       Date 12  2004-080  7/23/2004  The proposed changes to the WCGS        Closed      The licensee implemented the Technical Specifications (eliminating   (No date in changes to the Technical requirement for hydrogen recombiners   CMS,        Specifications and Technical and hydrogen monitors) will be         incorrectly Specification Bases.
Closed11/06/2006The licensee notified theProject Manager (Jack Donohew) by email on 11/06/2006.
implemented within 90 days of NRC       listed as approval. Revision to the TS Bases will Open) be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment.
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.
13  2004-081  7/23/2004  WCNOC has verified that a hydrogen      Closed      Hydrogen monitors have been monitoring system capable of diagnosing (No date in included in the Technical beyond design-basis accidents is       CMS,        Requirements Manual.
installed at WCGS and is making a       incorrectly regulatory commitment to maintain that listed as capability. The hydrogen monitors will Open) be included in the Technical Requirements Manual. This regulatory commitment will be implemented within 90 days of NRC approval of this amendment request.
14  2005-107  7/31/2005  Submit an update to information        Closed      The licensee submitted the contained in WCNOCs response to       5/31/2006  information requested in letter Generic Letter 2004-02 Requested                   WO 06-0028.
Information Item 2.
15  2006-237  9/27/2006  WCNOC will notify the NRC Project      Closed      The licensee notified the Manager for Wolf Creek Generating       11/06/2006  Project Manager (Jack Station (WCGS) when the ultrasonic                 Donohew) by email on (UT) examination of the final full                 11/06/2006.
structural weld overlay is complete.
Item Commitment Commitment Description of Commitment                  Status      Method of Closure No. No.       Date 16  2006-238  9/27/2006  WCNOC will provide the results of the      Closed      The results of the UT UT examinations of the full structural     11/17/2006  examinations were provided in weld overlays of the WCGS Pressurizer                   letter ET 06-0055.
safety, relief, spray and surge line nozzle welds to the NRC.
The results will include:
The results will include:
* A listing of indications detected;
* 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 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.
* 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.
17   Not in CMS 4/18/2005  If cracking is found in the sample          Closed      The inspection was performed population of bulges or overexpansions,     (No date in by Westinghouse Electric the inspection scope will be increased to   CMS)        Corporation on 4/22/2005, the 100% of the bulges and overexpansions                   results of which were reported population for the region from the top of               to the NRC in letter ET the hot leg tubesheet to 17 inches below               06-0016.
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.
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.
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.,
Item Commitment Commitment Description of Commitment                    Status      Method of Closure No. No.       Date 18  Not in CMS 4/18/2005  If cracking is reported at one or more      Closed      Since no cracking was tube locations not designated as either a   (No date in reported, no action was top of the tubesheet expansion               CMS)        required to fulfill this transition, a bulge or an overexpansion,                 commitment.
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.
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.
19  Not in CMS 6/26/2006  The license amendment (to remove            Closed      The licensee implemented the containment atmosphere gaseous               (No date in changes to the Technical radioactivity monitor from Technical        CMS)        Specifications and Technical Specification 3.14.15) will be                           Specification Bases.
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.
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
Table 2. Revised or Deleted Regulatory Commitments Item Commitment Commitment Description of Commitment Change to Commitment Reported                Evaluation No. No.       Change Date                                                              to NRC? Consistent with Procedure?
 
20  1997-179  5/10/2006    The Plant Manager will          Work hour limitations will Yes    Yes establish a performance          be tracked in the cross indicator on approved work      functional team panels.
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.
hour deviations. This            The Plant Manager will indicator is a tool for          remain cognizant of any management monitoring of        deviations through authorization frequency and      review of the division justification.                  clock resets and related Condition Reports.
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,"
21  1997-181  5/10/2006    Procedure AP 13-001,             Procedure was changed      Yes    Yes Revision 2, Guidelines for     to state that work hour WCGS Staff Working Hours,       limitations will be will be enhanced to provide     included in the cross better guidance.                functional team panels.
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
22  1986-265  12/10/2003    Compliance with                  Commitment remarks        No      Yes administrative controls [for     was edited to provide combustible materials] will be   clarification of the maintained by increased         implementation of the inspections by the station fire commitment.
 
protection specialist.
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
23  2003-032  8/5/2004      WCNOC will revise                Additional guidance is    No      Yes administrative controls for     implemented by a monitoring and evaluating the   second procedure to containment atmosphere to       provide specific visual require initiation of corrective inspection parameters, action documentation when       limits, and notes to sample results indicate         define specific actions potential RCS leakage or         needed based on the changes to RCS leakage.         results.
 
Attachment 2
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}}
Item Commitment  Commitment  Description of Commitment    Change to Commitment Reported    Evaluation No. No.          Change Date                                                        to NRC? Consistent with Procedure?
24  Not Assigned 2/6/2004    Following an unscheduled      Only the Plant Safety     No      Yes reactor shutdown, the         Review Committee will Independent Safety            review the post-trip Evaluation Group (ISEG) is    review, in fulfillment of responsible for performing an requirement 1.1 of independent evaluation of the Generic Letter 83-28, unscheduled reactor trip data Required Actions Based package in the same manner    on Generic Implications as the Plant Safety Review    of Salem ATWS Events.
Committee.
                                                    }}

Latest revision as of 10:52, 13 March 2020

Audit Report of Licensee Regulatory Commitment Management Program for Audit Performed August 20-21, 2007
ML072780003
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 10/31/2007
From: Donohew J
NRC/NRR/ADRO/DORL/LPLIV
To: Muench R
Wolf Creek
Donohew J N, NRR/DORL/LP4, 415-1307
References
TAC MD6619
Download: ML072780003 (16)
v • d • e


Text

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

SUBJECT:

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

Dear Mr. Muench:

An audit of the Wolf Creek Nuclear Operating Corporation (WCNOC) regulatory commitment management 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 Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosure:

Audit Report cc w/encl: See next page

ML072780003 OFFICE NRR/SNPB NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME AHoffman JDonohew JBurkhardt THiltz DATE 10/22/07 10/24/07 10/11/07 10/31/07 Wolf Creek Generating Station cc:

Jay Silberg, Esq. Chief, Radiation and Asbestos Control Pillsbury Winthrop Shaw Pittman LLP Section 2300 N Street, NW Kansas Department of Health Washington, D.C. 20037 and Environment Bureau of Air and Radiation Regional Administrator, Region IV 1000 SW Jackson, Suite 310 U.S. Nuclear Regulatory Commission Topeka, KS 66612-1366 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corporation Senior Resident Inspector P.O. Box 411 U.S. Nuclear Regulatory Commission Burlington, KS 66839 P.O. Box 311 Burlington, KS 66839 Supervisor Licensing Wolf Creek Nuclear Operating Corporation Chief Engineer, Utilities Division P.O. Box 411 Kansas Corporation Commission Burlington, KS 66839 1500 SW Arrowhead Road Topeka, KS 66604-4027 U.S. Nuclear Regulatory Commission Resident Inspectors Office/Callaway Plant Office of the Governor 8201 NRC Road State of Kansas Steedman, MO 65077-1032 Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839 February 2006

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482

1.0 INTRODUCTION AND BACKGROUND

In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing 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 to the NRC.

The NRC staff has agreed that NEI 99-04 provides acceptable guidance to licensees for the control 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 regulatory commitments made by commercial reactor licensees. An NRR project manager audits the licensees CMP by assessing the adequacy of the licensees 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 RESULTS An audit of the Wolf Creek Nuclear Operating Corporations (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 Licensees 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 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 were approved 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 licensees CMS along with other relevant documentation 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 licensees 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 Licensees Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensees performance related to implementing controls 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 licensees programs and procedures, that the licensees 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, Commitment Management 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 in ATTACHMENT 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 the NRC. 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 licensees 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 outgoing correspondence 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 licensees commitment tracking software as a part of their document management 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 or absent 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 adequate program 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 AUDIT Bill Muilenberg Attachments:

1. Table 1: Implemented Regulatory Commitments
2. Table 2: Revised or Deleted Regulatory Commitments Principal Contributor: Adam Hoffman, NRR Date: October 31, 2007

AUDIT OF WOLF CREEK NUCLEAR OPERATING CORPORATION (WCNOC)

MANAGEMENT OF REGULATORY COMMITMENTS AT WOLF CREEK NUCLEAR GENERATING STATION PERFORMED AUGUST 20-21, 2007 LIST OF COMMITMENTS INCLUDED IN AUDIT Table 1. Implemented Regulatory Commitments Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 1 2001-026 11/14/2001 WCNOC will provide the requested Closed During refueling outage 12, a information (NRC Bulletin 2001-01, 5/22/2002 remote visual inspection of the Request 5) or indicate no leakage was top of the reactor vessel head found, within 30 days after plant restart was performed to support an following the next refueling outage. 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).

Attachment 1

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 2 2002-025 12/4/2002 WCNOC will conduct a MRP inspection Closed This commitment was plan supplemental visual examination (No date in superseded by NRC Revised in Refueling Outage #14, currently CMS) Order EA-03-009, Issuance of scheduled for spring 2005. First Revised Order (EA-03-009) Establishing Interim Inspection Requirements For Reactor Pressure Vessel Heads at Pressurized Water Reactors.

3 2003-058 9/19/2003 A surveillance procedure for inspection Closed The required elements of the lower RPV head will be developed 12/12/2003 developed for the lower head and will include the following elements: inspection are contained in a

  • Use of VT-2 examination techniques surveillance procedure.
  • 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 4 2003-059 9/19/2003 A bare-metal visual inspection of the Closed The appropriate surveillance lower RPV head will be performed. 11/27/2003 procedure was performed.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 5 2003-060 9/19/2003 WCNOC will submit to the NRC: Closed The required information was

  • a summary of the inspections (No date in provided in licensee submittal performed, CMS) WM 04-0002.
  • the extent of the Inspections,
  • the methods used,
  • a description of the as-found condition of the lower head,
  • a summary of the disposition of any findings of boric acid deposits and any corrective actions taken as a result of indications found.

6 2003-066 12/15/2003 The proposed changes to the WCGS Closed NRC issued Amendment No.

Technical Specifications (Reactor Trip (No date in 156 on 1/31/2005.

System Instrumentation and Engineered CMS) Amendment No. 156 was Safety Features Actuation System implemented on 2/16/2005.

Instrumentation) will be implemented within 90 days of NRC approval.

7 2003-067 12/15/2003 Activities that degrade the availability of Closed These restrictions have been the auxiliary feedwater system, RCS (No date in implemented in procedures.

pressure relief system (pressurizer CMS)

PORVs and safety valves), AMSAC, or turbine trip should not be scheduled when a logic train or RTB train is inoperable for maintenance.

8 2003-068 12/15/2003 One complete ECCS train that can be Closed This restriction has been actuated automatically must be (No date in implemented in procedures.

maintained when a logic train is CMS) inoperable for maintenance.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 9 2003-069 12/15/2003 Activities that cause master relays or Closed These restrictions have been slave relays in the available train to be (No date in implemented in procedures.

unavailable and activities that cause CMS) analog channels to be unavailable should not be scheduled when a logic train or RTB train is inoperable for maintenance.

10 2003-070 12/15/2003 Activities on electrical systems (e.g., AC Closed These restrictions have been and DC power) and cooling systems (No date in implemented in procedures.

(e.g., essential service water and CMS) 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.

11 2003-071 12/15/2003 The drift term used in the WCGS Closed I&C is required to collect this setpoint study was originally based on a (No date in information with each 30 day surveillance interval for COTs. CMS) surveillance. Trends are From historical experience, instrument monitored and the results are drift is expected to remain within the provided to Safety Analysis.

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.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 12 2004-080 7/23/2004 The proposed changes to the WCGS Closed The licensee implemented the Technical Specifications (eliminating (No date in changes to the Technical requirement for hydrogen recombiners CMS, Specifications and Technical and hydrogen monitors) will be incorrectly Specification Bases.

implemented within 90 days of NRC listed as approval. Revision to the TS Bases will Open) be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment.

13 2004-081 7/23/2004 WCNOC has verified that a hydrogen Closed Hydrogen monitors have been monitoring system capable of diagnosing (No date in included in the Technical beyond design-basis accidents is CMS, Requirements Manual.

installed at WCGS and is making a incorrectly regulatory commitment to maintain that listed as capability. The hydrogen monitors will Open) be included in the Technical Requirements Manual. This regulatory commitment will be implemented within 90 days of NRC approval of this amendment request.

14 2005-107 7/31/2005 Submit an update to information Closed The licensee submitted the contained in WCNOCs response to 5/31/2006 information requested in letter Generic Letter 2004-02 Requested WO 06-0028.

Information Item 2.

15 2006-237 9/27/2006 WCNOC will notify the NRC Project Closed The licensee notified the Manager for Wolf Creek Generating 11/06/2006 Project Manager (Jack Station (WCGS) when the ultrasonic Donohew) by email on (UT) examination of the final full 11/06/2006.

structural weld overlay is complete.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 16 2006-238 9/27/2006 WCNOC will provide the results of the Closed The results of the UT UT examinations of the full structural 11/17/2006 examinations were provided in weld overlays of the WCGS Pressurizer letter ET 06-0055.

safety, relief, spray and surge line nozzle welds to the NRC.

The results will include:

  • A listing of indications detected;
  • 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.

17 Not in CMS 4/18/2005 If cracking is found in the sample Closed The inspection was performed population of bulges or overexpansions, (No date in by Westinghouse Electric the inspection scope will be increased to CMS) Corporation on 4/22/2005, the 100% of the bulges and overexpansions results of which were reported population for the region from the top of to the NRC in letter ET the hot leg tubesheet to 17 inches below 06-0016.

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.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 18 Not in CMS 4/18/2005 If cracking is reported at one or more Closed Since no cracking was tube locations not designated as either a (No date in reported, no action was top of the tubesheet expansion CMS) required to fulfill this transition, a bulge or an overexpansion, commitment.

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.

19 Not in CMS 6/26/2006 The license amendment (to remove Closed The licensee implemented the containment atmosphere gaseous (No date in changes to the Technical radioactivity monitor from Technical CMS) Specifications and Technical Specification 3.14.15) will be Specification Bases.

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.

Table 2. Revised or Deleted Regulatory Commitments Item Commitment Commitment Description of Commitment Change to Commitment Reported Evaluation No. No. Change Date to NRC? Consistent with Procedure?

20 1997-179 5/10/2006 The Plant Manager will Work hour limitations will Yes Yes establish a performance be tracked in the cross indicator on approved work functional team panels.

hour deviations. This The Plant Manager will indicator is a tool for remain cognizant of any management monitoring of deviations through authorization frequency and review of the division justification. clock resets and related Condition Reports.

21 1997-181 5/10/2006 Procedure AP 13-001, Procedure was changed Yes Yes Revision 2, Guidelines for to state that work hour WCGS Staff Working Hours, limitations will be will be enhanced to provide included in the cross better guidance. functional team panels.

22 1986-265 12/10/2003 Compliance with Commitment remarks No Yes administrative controls [for was edited to provide combustible materials] will be clarification of the maintained by increased implementation of the inspections by the station fire commitment.

protection specialist.

23 2003-032 8/5/2004 WCNOC will revise Additional guidance is No Yes administrative controls for implemented by a monitoring and evaluating the second procedure to containment atmosphere to provide specific visual require initiation of corrective inspection parameters, action documentation when limits, and notes to sample results indicate define specific actions potential RCS leakage or needed based on the changes to RCS leakage. results.

Attachment 2

Item Commitment Commitment Description of Commitment Change to Commitment Reported Evaluation No. No. Change Date to NRC? Consistent with Procedure?

24 Not Assigned 2/6/2004 Following an unscheduled Only the Plant Safety No Yes reactor shutdown, the Review Committee will Independent Safety review the post-trip Evaluation Group (ISEG) is review, in fulfillment of responsible for performing an requirement 1.1 of independent evaluation of the Generic Letter 83-28, unscheduled reactor trip data Required Actions Based package in the same manner on Generic Implications as the Plant Safety Review of Salem ATWS Events.

Committee.

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