ML090570036
| ML090570036 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/27/2009 |
| From: | Geoffrey Miller Plant Licensing Branch 1 |
| To: | Pardee C Exelon Generation Co |
| Miller, G. Edward, 415-2481 | |
| References | |
| RIS-00-017, TAC ME0362 | |
| Download: ML090570036 (10) | |
See also: RIS 2000-17
Text
UNITED NUCLEAR REGULATORY
WASHINGTON, D.C. 20555-0001
February 27, 2009 Mr. Charles G.
Pardee President
and Chief Nuclear Officer Exelon Generation
Company 4300 Winfield Road Warrenville, IL 60555 SUB..OYSTER CREEK NUCLEAR GENERATING
STATION (OCNGS) -AUDIT OF EXELON'S MANAGEMENT
OF REGULATORY
COMMITMENTS (TAC NO. ME0362) Dear Mr. Pardee:
In Regulatory
Issue Summary 2000-17, "Managing
Regulatory
Commitments Made by Power
Reactor Licensees to the NRC Staff," dated
September
21,2000, the U. S.
Nuclear Regulatory
Commission (NRC) informed licensees that the Nuclear Energy Institute
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 Requtation 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 regulatory
commitments are being
effectively
implemented. An audit of
OCNGS's commitment
management program was
performed
during January and February 2009, including
activities
at Exelon's office in
Kennett Square, PA on February 24, 2009. The NRC
staff concludes, based on the audit, that OCNGS has implemented
an acceptable program for
implementing
and managing NRC commitments. Details of the audit are set forth in the
enclosed audit report. G. dward Miller, Project Man ger Plant Licensing
Branch 1-2 Division of
Operating
Reactor Licensing Office of
Nuclear Reactor Regulation
Docket No. 50-219 Enclosure:
Audit Report cc w/encl: Distribution
via ListServ
UNITED NUCLEAR REGULATORY
WASHINGTON, D.C. 20555-0001
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION
LICENSEE MANAGEMENT
OF REGULATORY
COMMITMENTS
OYSTER CREEK NUCLEAR GENERATING
STATION DOCKET NO. 50-219 1.0 INTRODUCTION
AND BACKGROUND
In Regulatory
Issue Summary 2000-17, "Managing
Regulatory
Commitments
Made by Power Reactor Licensees to the NRC Staff," dated September
21,2000, the U. S.
Nuclear Regulatory
Commission (NRC) informed licensees that the Nuclear Energy Institute
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 regulatory
commitments are being
effectively
implemented.
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, reliefs, 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 Oyster Creek Nuclear Generating
Station (OCNGS) commitment
management
program was performed at the NRC Headquarters
using documentation
provided by the licensee and at the
licensee's
Kennett Square office during the period of January and February 2009. The
audit reviewed commitments
made since the
previous audit in January 2004. 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.
Enclosure
-2Verification
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. 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, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.).
Commitments made in Licensee
Event Reports or in response to Notices of Violation may be included in the sample, but the
review will be limited to verification of restoration of
compliance, not the specific methods used. Before the audit, the NRC
staff searched the
Agencywide
Documents Access and
Management
System (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: Commitments made on the
licensee's own initiative
among internal organizational
components. (Note: the internal
self-assessment
and subsequent transition to the Exelon Passport program was audited as an
indicator of the commitment to the process.) 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. 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. Audit Results Table 1 contains a list of those
documents that were selected for
additional
review during this
audit. The NRC staff found that the
licensee's
commitment
tracking program had captured all the
regulatory
commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant
procedures, assessment
recommendations, work orders, corrective
actions, training, qualification
certifications and action requests that had been initiated or revised as a result of
commitments made by the licensee to NRC. The program has a
requirement that the licensee perform an annual
review and assessment
of site and corporate
commitments. The most recent OCNGS annual
review was reviewed by the
-NRC staff. The annual review appeared thorough, addressing over 300 items. It identified isolated concerns with
procedure annotation. Further, the NRC
staff found that appropriate corrective actions were initiated.
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
OCNGS is contained in 110 -Revision 6, "Commitment
Management." The audit 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 audit also verifies 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 Table 1 contains a list of those
documents that were selected for
additional review during this
audit. The NRC staff reviewed the
licensee's procedure LS-AA-110, Revision 6,. Section 6.1 of the procedure lists NEI 99-04 as a reference. The NRC
staff found that LS-AA-11 0
generally follows the
guidance of NEI 99-04 and provides detailed
instructions for making regulatory commitments, tracking
regulatory
commitments, annotating
documents to provide
traceability
of commitments, and for making
changes to commitments.
Therefore, the NRC staff concludes that the procedure used by the
licensee to manage
commitments provides the
necessary attributes for an
acceptable
commitment
management
program. The NRC Staff noted that a
self-assessment had been performed since the last NRC audit and the potential concern identified in the previous NRC audit about the use of multiple
commitment
tracking systems was addressed.
Three recommendations from the self-assessment
were entered into the
commitment tracking program and acted upon. One of the
recommendations that OCNGS
transition to the Passport tracking program (Exelon
fleet-wide
system) from the use of multiple
programs addressed the previous potential concern.
Another recommendation
addressed
verification
of proper annotation after the transfer. Related
procedure
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport," was also reviewed. The NRC staff also reviewed
documents that had been created or revised as a result of
commitments made by the
licensee to the NRC. The
staff noted that, except as noted below, the revised
documents
have annotations referring to
commitments as part of the
commitment change control process.
These annotations serve to prevent the
commitments
from inadvertently being deleted or altered without having gone through the
commitment
change process. The NRC observed that in response to one
commitment (Item 1 in Table 1)
-emergency
procedures were revised, an operations briefing
developed and the training program augmented. It was
further observed that one of the revised
procedures, 2000-GLN-3200.01 (Plant Specific
Technical
Guidelines for the Symptom Based
Emergency Operating Procedures) was annotated
consistent with the procedural requirements. However, the "EOP Support
Procedure
7" referenced in the
commitment (and referenced by
2000-GLN-3200.01) was not annotated. As a result of
discussions during this audit, an entry was made into the corrective action program to evaluate the annotation
requirements
and determine if there are any extended implications.
3.0 CONCLUSION As discussed above, the
licensee's procedure used to
implement and manage commitments provides the
necessary
attributes for an acceptable
commitment
management
program. 4.0 LICENSEE PERSONNEL
CONTACTED FOR THIS AUDIT Richard Gropp
Calvin Taylor John Hufnagel Pam Cowan Principal Contributor: D. Egan
-Item Source Commitment
Timeframe
Comments 1 Source: 1/24/07 letter 20448, Summary of Commitments. Second item. (ML07031 01010) Oyster Creek [emergency
operations
procedure]
EOP Support Procedure 7 will be revised to direct the
Operator to inject the entire
contents of the Liquid Poison tank in the event that a [loss
of coolant accident]
LOCA is in progress. Include these EOP
changes and their basis in Licensed
Operator Training, and update the EOP User's Guide to include the use of sodium pentaborate for pH control of the
suppression
pool under LOCA conditions.
Upon implementation
of approved amendment.
Procedure
EMG-SP7 -not annotated (revised parent document annotated)
RCMT 189765-48
2 Source: 7/3/08 letter 060, Attachment 2. First item on page 9 and last
item on page 10. (ML0819308020) First item on page 9:
Oyster Creek will
follow the guidelines in Section
11.3.6.5 of NUMARC 93-01, Rev. 3 during refueling within
containment.
Plant procedures will be revised, as
appropriate, to implement
these guidelines. Last item on oaae 10: The
following
secondary
containment
potential
openings will remain closed during refueling activities
under administrative
controls:
- Ventilation
ductwork below siding
structure
on west side of
Reactor Building (north end of west
wall) * Ventilation
ductwork below siding
structure
on west side
of Reactor Building (south end of west
wall) * Trunion Room Doors to
Turbine Building * Reactor Building
Commodities (flanged) penetration on north RB wall
- MAC Facility Doors
Upon implementation
of approved amendment. Note: This
License Amendment
Request has not been approved.
The commitments
associated with License
Amendment
Request are being tracked
under Passport Action Requests 642132 and 828005. This issue is still
under review by the NRC. The
commitments
associated
with this License
Amendment
Request will be implemented
as approved by the NRC.
Table 1
-6 Item Source Commitment
Timeframe
Comments 3 Source; 2/2/07 letter 20450, Page 4.
Corrective action planned
item. (ML0703803170) The new pressure switch
performance will be monitored for a year to
determine
if periodic replacement of the pressure switches is
warranted. One year after
[license event report] LER
submittal.
IR 567038 -Actions initiated by the corrective
action program have resulted in
identifying
adverse trends on
[electromagnetic relief valve]
EMRV instruments.
Actions initiated by the [corrective
actions] have resulted in
implementing
replacement
of the pressure switches and control relays and
establishing
routine replacement
[preventative
maintenance]
tasks. 4 Source: 3/28/05 letter 20040, Page 1
of attachment. Item listed (ML0509042340) To ensure that the
Standby Liquid Control system is initiated in the event of a [large break] LOCA, the
Oyster Creek [EOPs] will be revised as required. Within 90 days of NRC issuance of license amendment.
Procedures
EMG-SP7, 3200.01 (refer also to Item 1)
RCMT 189765-48
Table 1
-7 Item Source Commitment
Timeframe
Comments 5 Source: 3/31/05 letter 20062, Attachment
2. Second item. (ML0509600680) Revise the
administrative
procedure for control
of EOP documents (CC-AA-309, Control of Design
Analysis)
to include instructions to use the
appropriate
configuration control process to revise the plant
specific technical
guidelines (PSTG) Appendix C criteria.
CAP 1986-12 was
completed
on 12/02/2004
AD-OC-103, "EOP/SAM [severe accident mitigation] Program Control," includes
annotations associated with
the implementation of this commitment.
- Section 4.1.3.13 -Any change to a design input, setpoint, used in
Appendix C to the PSTGs shall be
controlled
in accordance with CC-AA-102, "Design Input and
Configuration
Change Impact Screening.
2) * Section 4.1.3.14 -All changes to the calculations
in Appendix C to the PSTGs shall be
controlled
in accordance with Procedure 309, "Control of Design
Analyses." (CM-2) RCMT 620989-05
Table 1
-8 Item Source Commitment
Timeframe
Comments 6 Source: Attachment 3 of Self-Assessment. Page 7, second and third
DC items and Page 10 -DC items. Page 7 * Verification of
proper annotation of
current commitments using
PassPort after data transfer.
(487012-10)
- Transfer of data to
PassPort and train site on
proper commitment
management.
(487012-10) Page 10 * Lotus Notes
Database currently not site-wide searchable and known
commitments may be missed. (IR 380386)
Actions Completed
IR 487012-10 (references
IR 528865-48)
IR 380386 -01,02,03,04, and 05 Internal actions completed as a result of
self-assessment
7 Commitment
Change Evaluation
Forms. * Commitment
Tracking Numbers08-006, R1,08-002
Procedural
requirements
completed
Attachment 1 from 110 Commitment
changes requiring both the need to inform and not inform NRC
Table 1
Mr. Charles G. Pardee President and
Chief Nuclear Officer Exelon Generation
Company 4300 Winfield Road Warrenville, IL 60555 OYSTER CREEK NUCLEAR GENERATING
STATION (OCNGS) -AUDIT OF EXELON'S MANAGEMENT
OF REGULATORY
COMMITMENTS (TAC NO. ME0362) Dear Mr. Pardee: In Regulatory Issue
Summary 2000-17, "Managing
Regulatory
Commitments Made by Power
Reactor Licensees to the NRC Staff," dated
September
21,2000, the U. S.
Nuclear Regulatory
Commission (NRC) informed
licensees that the Nuclear Energy Institute
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 regulatory
commitments are being
effectively
implemented. An audit of
OCNGS's commitment
management program was
performed during January and February 2009, including
activities at Exelon's office in Kennett Square, PA on February 24, 2009. The NRC
staff concludes, based on the audit, that OCNGS has
implemented
an acceptable program for
implementing and managing NRC
commitments. Details of the audit are set forth in the
enclosed audit report.
Sincerely, G. Edward Miller, Project
Manager Plant Licensing Branch
1-2 Division of Operating
Reactor Licensing Office of
Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Audit Report cc w/encl: Distribution
via ListServ DISTRIBUTION:
Public LPL1-2 Reading
Resource RidsAcrsAcnw_MailCTR
Resource RidsNrrDorlLpl1-2
Resource RidsNrrPMEMiller
Resource RidsNrrLAABaxter
Resource RidsOgc Resource
RidsRgn1 MailCenter
Resource RidsNrrDorlDpr
Resource ACCESSION
No'.. ML090570036 NRR-106 * via email
OFFICE LPLI-2\PM
LPLI-2\PM
LPLI-2\LA
LPLI-2\BC
NAME GMiller DEgan ABaxter HChernoff
DATE 2/27109 02/26/09 02/27/09*
2/27109 OFFICIAL RECORD