ML063550037

Response to Apparent Violation in Inspection Report 05000266/2006011; 0500301/2006011; EA-06-274

ML063550037
Person / Time
Site:	Point Beach
Issue date:	12/19/2006
From:	Koehl D Nuclear Management Co
To:	Document Control Desk, NRC/RGN-III
References
EA-06-274, NRC 2006-0080
Download: ML063550037 (7)

See also: IR 05000266/2006011

Text

Point Beach Nuclear Plant Committed

to Nuclear Excellence

Operated by Nuclear Management

Company, LLC December 19,2006 NRC 2006-0080

10 CFR 2.201 U.S. Nuclear Regulatory

Commission

ATTN: Document Control Desk Washington, DC 20555-0001

Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Response to an Apparent Violation

in Inspection

Report 05000266/2006011~

0500301 /2006011;

EA-06-274

Reference:

(1) Letter from NRC to NMC dated November 21, 2006 As a result of inspections

conducted

by the U. S. Nuclear Regulatory

Commission (NRC) between April 1, 2006, and October 27, 2006, an Apparent Violation

of NRC requirements

contained

in 10 CFR 50.71 (e) and a non-cited

violation

were documented

in Reference

(1). The Apparent Violation

states that the Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR) was not updated in 1983 with the results of a reactor vessel head (RVH) drop analysis conducted

in 1982. It further states that in response to NRC questions

in 2005, Nuclear Management

Company LLC (NMC) made the determination

that amendments

to the PBNP Operating

Licenses were necessary

prior to updating the FSAR with this analysis, and furthermore, that administrative

controls for the movement of the PBNP RVHs were needed. These amendments

and administrative

controls were not in place for RVH moves from 1983 through 2004. Pursuant to the provisions

of 10 CFR 2.201, Nuclear Management

Company, LLC is responding

to the Apparent Violation

in the enclosure

to this letter. NMC concurs that the Apparent Violation

has been properly characterized

as a violation

of the requirements

of 10 CFR 50.71 (e). 6610 Nu~lear Road Two Rivers, Wisconsin

54241-9516

Telephone:

920.755.2321

Document Control Desk Page 2 Summary of Regulatory

Commitments

This letter contains no new commitments

and no revisions

to existing commitments:

Dennis L. Koehl / Site Vice-President, Point Beach Nuclear Plant Nuclear Management

Company, LLC Enclosure

cc: Administrator, Region Ill, USNRC Enforcement

Officer, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC

ENCLOSURE

Response to an Apparent Violation

in lnspection

Report 050002661200601

1 ; 0500301/2006011;

EA-06-274

Pursuant to the provisions

of 10 CFR 2.201, the following

is the NMC response to an Apparent Violation (EA-06-274)

of NRC requirements

as documented

in NRC lnspection

Report 05000266/2006011;

0500301/200601

dated November 21,2006. APPARENT VIOLATION

Contrary to the requirements

of 10 CFR 50.71 (e), the Point Beach Nuclear Plant (PBNP) Final Safety Analysis Report (FSAR)

was not updated in 1983 with the results of a reactor vessel head (RVH) drop analysis conducted

in 1982. Evaluation

of this analysis by Nuclear Management

Company, LLC (NMC) in 2005, in response to questions

from the NRC, resulted in NMC's determination

that amendments

to the PBNP Operating

Licenses were necessary

prior to updating the FSAR with this analysis.

This evaluation

also concluded

that the establishment

of administrative

controls on the movement of the PBNP reactor vessel heads (RVHs) was required.

The amendments

and administrative

controls were not in place for RVH moves from 1983 through 2004. NMC RESPONSE NMC concurs that the failure to update the FSAR in accordance

with the requirements

of 10 CFR 50.71 (e) was a violation

of NRC requirements.

Reasons for Violation:

There have been several evaluations

performed

to determine

the reasons for this Apparent Violation.

A description

of each of these evaluations

and its conclusions

is provided below. 1. Root Cause Evaluation (RCE) 277, Reactor Vessel Head Drop Analysis RCE 277, Reactor Vessel Head Drop Analysis, was performed

to identify the historical

and present-day

issues relating to the absence of a design basis or licensing

basis analysis of record for a reactor vessel head (RVH) drop accident.

Page 1 of 5

2. RCE 300, Personnel

Awareness

and Understandina

of Licensina

Bases RCE 300, Personnel

Awareness

& Understanding

of Licensing

Bases, was chartered

in early December 2005, as a result of a streaming

analysis pelformed

by the PBNP senior management

team in late November 2005. RCE 300, Revision 1, was issued on April 27, 2006. The purpose of this RCE was to determine

the root and contributing

causes for the limited awareness

and inadequate

understanding

of regulatory

commitments

and requirements, including

legacy issues, such that docketed correspondence

has not always been incorporated

into licensing

basis documents, such as the FSAR. Additionally, the RCE evaluated

why regulatory

commitments

contained

in the correspondence

have not always been adequately

translated

into license basis implementing

documents

such as procedures.

3. PBSA-ENG-05-04, 10 CFR 50.59 Focused Self-Assessment

and Common Factors Assessment

A focused self-assessment

of implementation

of the 10 CFR 50.59 process at PBNP was conducted

on October 10-28,2005.

The purpose of the self-assessment

was to prepare for the baseline inspection

in December 2005, as well as to evaluate the effectiveness

of training conducted

in August 2005. One result of the self-assessment

was completion

of a common factors analysis (CFA) in order to determine

why some previous corrective

actions had not been effective.

The Common Factors Assessment (CFA) was conducted

during February 2006. 4. Common Cause Evaluation (CCE) of Component

Desiqn Basis Inspection (CDBI) Corrective

Action Documents

The purpose of this CCE was to obtain additional

insights into PBNP design and licensing

basis issues. The CCE confirmed

the conclusions

of RCE 300 with respect to its finding that design and licensing

basis information

is fragmented

and that additional

attention

should be placed on the preparation, review and approval of procedures

that implement

design requirements

to ensure these requirements

are appropriately

mapped. The reasons for the Apparent Violation

are: Activities

associated

with the design and licensing

basis were not elevated to a level of importance

such that the processes

and procedures

produce predictable

successful

outcomes.

The NMC RVH replacement

team failed to provide requested

information

on the RVH analysis to the vendor. Personnel

did not understand

the hierarchy

of the plant's licensing

and design bases within the regulatory

framework

of Title 10, Code of Federal Regulations.

Page 2 of 5

The processes

intended to implement

the regulations

were fragmented

and insufficient

to ensure that design and license basis requirements

were properly mapped into their respective

implementing

documents.

In the case of the reactor vessel head replacement

project, there were no internal processes

and procedures

to effectively

govern conduct of the project. Clear ownership, roles and responsibilities

associated

with license basis maintenance

and control were not clearly defined. Corrective

Steps Taken and Results Achieved:

Corrective

steps were taken to address issues specific to the RVH drop analysis and the non-cited

violation

of 10 CFR 50.59. These corrective

steps are summarized

as follows: 1. On April 16, 2005, commitments

were made by NMC to NRC that provided compensatory

measures to enable movement of the original RVH. These commitments

were formalized

via letter NRC 2005-0050A

dated April 20, 2005, and subsequently

implemented.

2. On April 29, 2005, an application

for a proposed amendment

was submitted

to the Commission

via letter NRC 2005-055.

This application

was supplemented

by letters dated May 13, May 19, June 1, June4, June 9, June 20, and June 23,2005. 3. On June 24, 2005, NMC issued TRM 3.9.4, Reactor Vessel Head Lift, which provides required administrative

controls during lifting of a RVH over a reactor containing

fuel assemblies.

At the time of issue, TRM 3.9.4 was applicable

only to Unit 2. 4. On July 24, 2005, NMC requested

a similar amendment

for Unit 1 via letter NRC 2005-0094.

5. On August 15, 2005, the Unit 2 RVH drop analysis was incorporated

into the FSAR and submitted

to the NRC via the periodic FSAR update as required by 10 CFR 50.71 (e). 6. On September

23, 2005, TRM 3.9.4 was revised to reflect provisions

of the NRC Safety Evaluation

which delineated

administrative

controls during lifting of a RVH over a reactor containing

fuel assemblies.

This revision of TRM 3.9.4, therefore, applied to both PBNP units. 7. On August 15,2006, the PBNP FSAR was revised and submitted

to the NRC during the periodic update of the FSAR as required by 10 CFR 50.71 (e) to reflect applicability

for both units. Page 3 of 5

8. Affected plant implementing

documents

such as Safe Load Path guidance for movement of heavy loads, RVH routine maintenance

procedures

used during each refueling

outage, Operations

containment

closure checklists

and refueling-related

procedures, etc., have been revised. 9. The NMC Project Management

Manual has been implemented

at PBNP. 10. A current licensing

basis (CLB) policy was developed

and issued on June 20, 2006. The policy defines and describes

the CLB; establishes

ownership

of CLB documents;

defines personnel

roles and responsibilities

for implementing

and maintaining

the CLB; establishes

expectations

for use and adherence

to the CLB; and describes

available

tools and methods for searching

the CLB. 11. A training needs assessment

for the CLB policy was completed

and concluded

that informational

sharing and/or formal training sessions were required for appropriate

station personnel.

Lesson plans have been developed

and approved.

Engineering, Regulatory

Affairs and 10 CFR 50.59 screening

and evaluation-qualified

personnel

received training during August 2006. 12. Corrective

actions identified

in the December 2005 10 CFR 50.59 self-assessment

were incorporated

into the Engineering

Continuing

Training Program. The revised training was provided to engineering

in August 2006. 13. A continuing

training module was developed

and conducted

with engineering

personnel

to develop a common understanding

of the definition

and vision of technical

rigor and to provide personnel

with an awareness

of the available

human performance

tools to improve technical

rigor. Training was completed

in December 2006. 14. The licensee response to the October 9, 1996, NRC "Request for lnformation

Pursuant to 10 CFR 50.54(f) Regarding

Adequacy and Availability

of Design Basis Information," was reviewed.

A validation

package was compiled supporting

the licensee response dated February 6, 1997. Following

this effort, a "living validation

package" was compiled which reflected

the 2006 status of statements

of fact contained

in the response.

15. A procedures

writerlreviewer

certification

matrix, along with a Job Familiarization

Guide (JFG), was developed

and is being implemented.

In addition, as part of this certification

process, information

sharing sessions are being conducted

to provide personnel

involved in procedure

writing and reviewing

with "hands-on" practical

experience

in searching

the site's Regulatory

lnformation

System, which includes the Regulatory

Commitment

Database.

16. Ownership

of the FSAR was transferred

from Engineering

to Regulatory

Affairs on December 15,2006. Page 4 of 5

Corrective

Steps To Be Taken: There are no additional

corrective

actions required to address this violation.

Date Full Compliance

Will Be Achieved:

Full compliance

with NRC requirements

was achieved on August 15, 2006, for both units when the vessel head drop analysis for Unit 1 was incorporated

into the FSAR. Page 5 of 5