ML14042A220

Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed December 16-18, 2013

ML14042A220
Person / Time
Site:	Wolf Creek
Issue date:	02/21/2014
From:	Lyon C Plant Licensing Branch IV
To:	Heflin A Wolf Creek
Lyon C
References
TAC MF2971
Download: ML14042A220 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 21, 2014 Mr. Adam C. Heflin President, Chief Executive Officer, and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION- AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF2971)

Dear Mr. Heflin:

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

An audit of the Wolf Creek Generating Station commitment management program was performed at the plant site during the period December 16-18, 2013. Based on the audit, the NRC staff concludes that Wolf Creek Nuclear Operating Corporation (the licensee) has implemented NRC commitments on a timely basis and has implemented its program for managing NRC commitment changes. The details of the results of the audit are set forth in the enclosed audit report.

I appreciate the assistance and support provided by your licensing staff during the audit, particularly Mr. Steve Wideman, Mr. Bill Muilenburg, and Ms. Nicole Good.

A. Heflin If you have any questions, please contact me at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosure:

Commitment Audit Report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482

1.0 INTRODUCTION AND BACKGROUND

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

NEI-99-04 defines a "regulatory commitment" as 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.

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Wolf Creek Generating Station (WCGS) commitment management program was performed at the plant site during the period December 16-18, 2013. The audit reviewed commitments made by Wolf Creek Nuclear Operating Corporation (WCNOC, the licensee) since the previous audit on August 17-19, 2010, which were documented in an audit report dated Enclosure

October 29, 2010 (ADAMS Accession No. ML102770135). The NRR Project Manager also reviewed the licensee's commitment changes as documented in Revisions 24, 25, and 26 to the WCGS Updated Safety Analysis Report, dated March 10, 2011, March 12, 2012, and March 11, 2013, respectively. The audit consisted of two major parts: (1) verification of the licensee's

• implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.

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 commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.

The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g.,

respond to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results The licensee's commitments are tracked in the Regulatory Commitment Management System (RCMS) computer database and are managed in accordance with WCGS procedure AI 26D-001, "Commitment Management System," Revision 9. For this audit, the NRC staff reviewed open and closed regulatory commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation as required by WCGS. The NRC staff reviewed relevant reports and summary sheets from the computer database and other

sources (e.g., corrective action documentation, plant procedures, job numbers, night orders, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. Based on the review of reports provided by the licensee as described above and on queries of the RCMS database during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis.

For this audit, the open commitments in the RCMS database were compared to licensee correspondence since the previous audit. No substantive deficiencies were noted. The auditor reviewed commitments closed since the last audit, and no discrepancies were noted. The auditors also reviewed the corrective actions for deficiencies noted in the last audit, and concluded that the corrective actions were appropriate to address the deficiencies.

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at WCGS is in accordance with WCGS procedure AI 260-001, "Commitment Management System," Revision 9. The auditors reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.2.1 Audit Results The NRC staff reviewed procedure AI 260-001 and associated procedures AI 26A-003, "Regulatory Evaluation (Other Than 10 CFR 50.59)," Revision 15, and AP 26A-004, "Communications with the [NRC]," Revision 20, and their required forms to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.

The NRC staff compared the guidance in the WCGS procedure AI 260-001 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the WCGS procedure was consistent with the NEI guidance for identifying, managing, and closing commitments. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in the WCGS procedure.

Based on the review of the reports provided by the licensee as described above, queries of the RCMS database, and the accompanying change review and tracking forms provided during the

audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes in accordance with its site procedure is satisfactory.

3.0 CONCLUSION

The NRC staff concludes, based on the audit, that (1) WCNOC has generally implemented NRC commitments on a timely basis, and (2) WCNOC has implemented its program for managing NRC commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Steve G. Wideman William T. Muilenburg Principal Contributor: F. Lyon Date: February 21, 2014

ML14042A220 OFFICE NRR/DORLILPL4-1 /PM NRR/DORLILPL4-1/LA N RR/DORLILPL4-1 /BC NRR/DORL/LPL4-1 /PM NAME Flyon JBurkhardt MMarkley Flyon DATE 2/18/14 2/13/14 2/20/14 2/21/14