ML082400005
| ML082400005 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/25/2008 |
| From: | Stang J Plant Licensing Branch II |
| To: | Christian D Virginia Electric & Power Co (VEPCO) |
| Lingam, Siva NRR/DORL 415-1564 | |
| References | |
| TAC MD9340, TAC MD9341 | |
| Download: ML082400005 (5) | |
Text
September 25, 2008
Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd. Glen Allen, VA 23060-6711
SUBJECT:
SURRY POWER STATION, UNIT NOS. 1 AND 2 - AUDIT OF VIRGINIA ELECTRIC AND POWER COMPANY'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD9340 AND MD9341)
Dear Mr. Christian:
On May 27, 2003, the Office of Nuclear Reactor Regulation issued Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]." 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 Institute's (NEI's) NEI 99-04, "Guidance for Managing NRC Commitment Changes." LIC-105 specifies that once every 3 years the NRC staff will audit a licensee's commitment management program.
On July 29, 2008, the NRC staff performed an audit of Virginia Electric and Power Company's (the licensee's) commitment management program at Surry Power Station, Unit Nos. 1 and 2. The NRC staff concludes that based on the audit (1) the licensee had implemented NRC commitments on a timely basis, and (2) the licensee 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. 50-280 and 50-281
Enclosure:
Audit Report
cc w/encl: See next page
ML082400005 NRR-106 OFFICE LPL2-1/PM LPD2-1/LA LPL2-1/BC NAME JStang MO
=Brien MWong DATE 9/17/08 -- 9/25/08 9/17/08 9/17/08 Enclosure AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-280 AND 50-281
1.0 INTRODUCTION
On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR) issued Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]." LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management System (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 Institute's (NEI's) 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 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 The regulatory commitment management audit was previously performed at Surry Power Station, Unit Nos. 1 and 2 (Surry 1 and 2) on July 22, 2004, covering the period of approximately 3 years to the date of the audit. The current audit was performed at Surry 1 and 2 on July 29, 2008, verifying the regulatory commitments made by Virginia Electric and Power Company (the licensee) between July 23, 2004, and July 28, 2008, for Surry 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.
2.1 Audit Scope
Before the audit, the NRC staff searched ADAMS for the licensee's licensing actions and licensing activities submitted between July 23, 2004, and August 28, 2008. Further, the licensee provided a list of the commitments made during the above period.
The licensee's 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 29, 2008, audit, the NRC staff reviewed the Plant Issue Resolution reports, Licensing Commitment reports, the licensee's 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 licensee's 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 licensee's 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 10 CFR 50.54.
2.2 Audit Results
The NRC staff reviewed reports generated by the Corrective Action System for the commitments made between July 23, 2004, and August 28, 2008, in order to evaluate the status of completion. The NRC staff found that the licensee's commitment tracking program had captured all of the pending regulatory commitments that were identified by the NRC staff.
2.3 Verification of the licensee's Program for Managing NRC Commitment Changes The NRC staff reviewed the licensee's 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 follow 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 licensee's information, as well as information from other sources, the NRC staff found no reason to differ from the licensee's 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 THE LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT B. Garber Principal Contributor: S. Lingam
Date: September 25, 2008
Surry Power Station, Unit Nos. 1 & 2 cc: Mr. David A. Christian President and Chief Nuclear Officer Virginia Electrical and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
Ms. Lillian M. Cuoco, Esq. Senior Counsel Dominion Resources Services, Inc. 120 Tredegar Street, RS-2 Richmond, VA 3219
Mr. Donald E. Jernigan Site Vice President Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883-0315 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission
5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218 Office of the Attorney GeneralCommonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Innsbrook Technical Center 5000 Dominion Blvd. Glen Allen, Virginia 23060-6711 Mr. Matt Adams, Director Nuclear Safety and Licensing Virginia Electric and Power Company Surry Power Station 5570 Hog Island Road Surry, Virginia 23883-0315
Mr. Curtis G. Luffman Manager Nuclear Protection Services Surry Power Station 5570 Hog Island Road Surry, VA 23883-0315
Mr. Barry Garber Supervisor Nuclear Engineering Surry Power Station 5570 Hog Island Road Surry, VA 23883-0315 Ms. Leslie N. Hartz, Vice President Nuclear Support Services Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 3060-6711 Mr. Nelson K. Martin Manager Nuclear Fleet Protection Services Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711