ML082400002

Audit of Virginia Electric and Power Company'S Management of Regulatory Commitments

ML082400002
Person / Time
Site:	North Anna
Issue date:	09/18/2008
From:	Siva Lingam Plant Licensing Branch II
To:	Christian D Virginia Electric & Power Co (VEPCO)
Lingam, Siva NRR/DORL 415-1564
References
TAC MD9338, TAC MD9339
Download: ML082400002 (7)

Text

September 18, 2008 Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 - AUDIT OF VIRGINIA ELECTRIC AND POWER COMPANYS MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD9338 AND MD9339)

Dear Mr. Christian:

On May 27, 2003, the Office of Nuclear Reactor Regulation, Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission], was issued. LIC-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institutes (NEIs) NEI 99-04, Guidance for Managing NRC Commitment Changes. LIC-105 specifies that once every 3 years the NRC staff will audit a licensees commitment management program.

On July 28, 2008, the NRC staff performed an audit of Virginia Electric and Power Companys (VEPCOs) commitment management program at North Anna Power Station, Unit Nos. 1 and 2.

The NRC staff concludes that based on the audit (1) VEPCO had implemented NRC commitments on a timely basis, and (2) VEPCO had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

Sincerely,

/RA/

John Stang, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosure:

Audit Report cc w/encl: See next page

ML082400002 NRR-106 OFFICE LPL2-1/PM LPD2-1/LA LPL2-1/BC NAME JStang MO=Brien MWong DATE 09 / 18 /08 09 / 17 /08 09 / 18 /08 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-338 AND 50-339

1.0 INTRODUCTION

On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR), Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission], was issued. LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Room on the Internet at the NRC web site (ADAMS Accession Number ML022750041), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by licensees for commercial nuclear reactors to the NRC staff. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institutes (NEIs) NEI 99-04, Guidance for Managing NRC Commitment Changes.

According to LIC-105, a regulatory 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 to audit the licensees commitment management program by assessing the adequacy of the licensees 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 PROCEDURE AND RESULTS The regulatory commitment management audit was previously performed at North Anna Power Station, Unit Nos. 1 and 2 (North Anna 1 and 2) on June 23, 2004, covering the period of approximately 3 years to the date of the audit. The current audit was performed at North Anna 1 and 2 on July 28, 2008, verifying the regulatory commitments made by Virginia Electric and Power Company (the licensee) between June 24, 2004, and July 25, 2008, for North Anna 1 and 2.

The primary focus of the audit was 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 ascertained that they had been captured in an effective program for future implementation.

Enclosure

2.1 Audit Scope Before the audit, the NRC staff searched ADAMS for the licensees licensing actions and licensing activities submitted between June 24, 2004, and July 25, 2008. Further, the licensee provided a list of the commitments made during the above period.

The licensees commitments are tracked by the Corrective Action System. The Corrective Action System is a computer database that is used to assign and track commitments to an effective completion. Commitments that are entered into the Corrective Action System are either tracked as a Plant Issue Resolution up to July 2006, or on a Commitment Data form from August 2006. During the July 28, 2008, audit, the NRC staff reviewed the Plant Issue Resolution reports, the licensees submittals, and other documents related to the commitments.

LIC-105 limits the audit of commitments to those made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Accordingly, the audit excluded the following types of commitments:

(1) Commitments as a result of Licensee Event Reports (LERs) - These commitments are controlled by the licensees LER process, which is imposed by Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.73.

(2) Commitments made on the licensees own initiative among internal organizational components and not reported to the NRC staff.

(3) Commitments integrated into the Updated Final Safety Analysis Reports, Quality Assurance Program, Site Security Plan, Emergency Plan, or other documents governed by a change control mechanism contained in regulations such as 10 CFR 50.59 or 50.54.

2.2 Audit Results The NRC staff reviewed reports generated by the Corrective Action System for the regulatory commitments made between June 24, 2004, and July 25, 2008, in order to evaluate the status of completion. The NRC staff found that the licensees commitment tracking program had captured all of the pending regulatory commitments that were identified by the NRC staff.

2.3 Verification of the Licensees Program for Managing NRC Commitment Changes The NRC staff reviewed the licensees procedure entitled Commitment Management, VPAP-2801, Revision 3, against NEI 99-04. Attachments 3 and 4 of VPAP-2801, Revision 3 provide details on the commitment management process that closely follows the guidance of NEI-99-04. In general, VPAP-2801, Revision 3 follows the guidance of NEI-99-04; it sets forth the need for identifying, tracking, and reporting commitments, and it provides a mechanism for changing commitments.

The NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of reviewing the licensees information, as well as information from other sources, the NRC staff found no reason to differ from

the licensees reported status of the audited commitments. Thus, the NRC staff concludes that the procedure used by the licensee to manage commitments is appropriate and effective.

3.0 CONCLUSION

The NRC staff concludes that based on the above audit: (1) the licensee had implemented, or is tracking for future implementation, regulatory commitments; and (2) the licensee had implemented an effective program to manage regulatory commitment changes.

4.0 VEPCO PERSONNEL CONTACTED FOR THIS AUDIT J. Leberstein Principal Contributor: S. Lingam Date: September 18, 2008

North Anna Power Station, Unit Nos. 1 & 2 Page 1 of 2 cc:

Mr. David A. Christian President and Chief Nuclear Officer Mr. Daniel G. Stoddard Dominion Nuclear Site Vice President Virginia Electric and Power Company North Anna Power Station Innsbrook Technical Center 1022 Haley Drive 5000 Dominion Boulevard Mineral, VA 23117 Glen Allen, VA 23060-6711 Dr. Robert B. Stroube, MD, MPH Mr. C. Lee Lintecum State Health Commissioner County Administrator Office of the Commissioner Louisa County Virginia Department of Health Post Office Box 160 Post Office Box 2448 Louisa, Virginia 23093 Richmond, Virginia 23218 Ms. Lillian M. Cuoco, Esq. Mr. Mark D. Sartain, Director Senior Counsel Nuclear Safety & Licensing Dominion Resources Services, Inc. Virginia Electric and Power Company 120 Tredegar Street, RS-2 North Anna Power Station Richmond, VA 23219 P.O. Box 402 Mineral, VA 23117 Dr. W. T. Lough Virginia State Corporation Commission Mr. Eugene S. Grecheck, Vice President Division of Energy Regulation Nuclear Development Post Office Box 1197 Innsbrook Technical Center Richmond, Virginia 23218 5000 Dominion Boulevard Glenn Allen, VA 23060-6711 Old Dominion Electric Cooperative 4201 Dominion Blvd. Mr. Marvin L. Smith, Project Director Glen Allen, Virginia 23060 Innsbrook Technical Center 5000 Dominion Boulevard Mr. Chris L. Funderburk, Director Glenn Allen, VA 23060-6711 Nuclear Licensing & Operations Support Dominion Resources Services, Inc. Mr. Timothy Maddy Innsbrook Technical Center Manager Nuclear Protection Services 5000 Dominion Blvd. North Anna Power Station Glen Allen, Virginia 23060-6711 1022 Haley Drive Mineral, VA 23117 Office of the Attorney General Commonwealth of Virginia Mr. Page Kemp 900 East Main Street Supervisor Nuclear Engineering Richmond, Virginia 23219 North Anna Power Station 1022 Haley Drive Senior Resident Inspector Mineral, VA 23117 North Anna Power Station U. S. Nuclear Regulatory Commission Ms. Leslie N. Hartz, Vice President P. O. Box 490 Nuclear Support Services Mineral, Virginia 23117 Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Page 2 of 2 Mr. Nelson K. Martin Manager Nuclear Fleet Protection Services Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711