ML12277A129
| ML12277A129 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/13/2012 |
| From: | Billoch-Colon A Plant Licensing Branch II |
| To: | Hamrick G Progress Energy Carolinas |
| Billoch-Colon, Araceli | |
| References | |
| TAC ME8191 | |
| Download: ML12277A129 (13) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 13, 2012 Mr. George Hamrick Vice President Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc.
Post Office Box 165, Mail Code: Zone 1 New Hill, NC 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. ME8191)
Dear Mr. Hamrick:
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 (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 if regulatory commitments are being effectively implemented.
An audit of Shearon Harris Nuclear Power Plant, Unit No.1 (Harris) commitment management program was performed at the plant site in New Hill, North Carolina, between July 23, and July 25,2012. The NRC staff concludes, based on the audit, that Harris (1) has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
G. Hamrick -2 Please direct any inquiries to me at 301-415-3302 or via email at AraceILBilloch@nrc.gov.
Sincerely, Araceli T. Billoch Colon, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400
Enclosure:
Audit Report cc w/encl: Distribution via ListServ
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SHEARON HARRIS NUCLEAR POWER PLANT. UNIT NO.1 DOCKET NO. 50-400
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 (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 if 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, 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 Shearon Harris Nuclear Power Plant, Unit No.1 (Harris) commitment management program was performed at the plant site in New Hill, North Carolina, between July 23 and July 25,2012. The audit reviewed commitments made since the previous audit completed between June 9 and June 11, 2008. 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 2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. It focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions or licensing activities. 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 its Agencywide Documents Access and Management System 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 (TSs), 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 attached Audit Summary provides details of the audit and its results.
The NRC staff reviewed the relevant plant procedure to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC. The procedure reviewed was REG-NGGC-011 0, "Regulatory Commitment." In addition, the NRC staff reviewed a sample of open and closed 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.
The NRC staff compared the guidance in procedure REG-NGGC-011 0 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the procedure implemented by the licensee is 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 REG-NGGC-011 0 procedure.
The licensee's commitments are tracked in a computer database called PassPort. Based on reports provided by the licensee and on queries of the PassPort database during the audit, the NRC staff found that PassPort is able to provide the necessary information (e.g., summary of the commitment, commitment type, lead department, responsible individual, due date, extensions, closure method and date, and associated historical information) to effectively manage NRC commitments.
- 3 For this part of the audit, the NRC staff reviewed site records associated with commitments involving, generic letters, bulletins, and license amendments to determine whether the licensee had implemented the closed commitments appropriately, and whether the licensee had established a success path for future implementation of the open commitments.
The NRC staff reviewed the documentation associated with the closed regulatory commitments, particularly plant procedures that had been revised as a result of the commitments, and found that the commitments reviewed had been closed in a manner that fully satisfied the commitments made to the NRC.
Based on the sample of commitments reviewed, the NRC staff found that commitments tracked in accordance with procedure REG-NGGC-011 0 were implemented satisfactorily. Also, based on the sample of licensee submittals and the NRC staff safety evaluations reviewed, the NRC staff found that commitments were tracked as specified by procedure REG-NGGC-011 O.
However, the NRC staff identified one instance where the licensee completed a commitment at a later date. This instance, as well as the summary of the overall results of the NRC staff review of the audit, is noted in the attached audit summary table. The licensee volunteered to document this instance in the Harris corrective action program for evaluation.
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 Harris is contained in the procedure REG-NGGC-0110.
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.
2.3 Review to Identify Misapplied Commitments The commitments reviewed for this audit were also evaluated to determine if they had been misapplied. A commitment is considered to be misapplied if the action comprising the commitment was relied on by the NRC staff in making a regulatory decision such as a finding of public health and safety in an NRC safety evaluation associated with a licensing action.
Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (Le., commitments used to ensure safety).
-4 Each of the commitments selected for the audit sample were reviewed to determine if any had been misapplied. No misapplied commitments were identified for Harris.
2.3.1 Review of Safety Evaluation Reports for Licensing Actions since the Last Audit to Determine if They Are Properly Captured as Commitments or Obligations In addition to the commitments selected for the audit sample, all license amendment safety evaluations, exemptions and relief request safety evaluations that have been issued for a facility since the last audit were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above.
The NRC staff reviewed the safety evaluations reports for the completed licensing actions since the last audit and no misapplied commitments were identified for Harris.
2.4 Audit Results The attached Audit Summary also provides details of this portion of the audit and its results.
The NRC staff found that procedure REG-NGGC-011 0 was consistent with the guidance found acceptable in NEI 99-04. The NRC staff concludes that the procedure used by the licensee to manage commitment changes is appropiate and that the licensee followed the process in their procedure.
The NRC staff reviewed the documentation associated with the changed commitments. The NRC staff observed that, Harris had complete records and documented changes, appropriately, which ensure the traceability of commitments.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) Harris has implemented NRC commitments on a timely basis, and (2) Harris has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT John Caves - Licensing and Regulatory Programs Shirelle Allen - Licensing and Regulatory Programs Principal Contributor: Araceli T. Billoch Colon
Attachment:
Summary of Audit Results
AUDIT
SUMMARY
LIST OF COMMITMENTS INCLUDED IN THE AUDIT No. Category Action Letter No. Letter Date Commitment Completion Notes Request No. &
Completion Date 1 Regulatory 270886 HNP-08-098 10/14/2008 The plant surveillance procedure OST-1107 was updated in Correspondence (OST-1107) will be revised to include the agreed timeframe on Generic Letter 12/17/2008 a requirement to secure the venting according to the (GL) 2008-01 process, to notify the SSO and to GL 2008-01 initiate an NCR in the event air or gas correspondence.
is detected during venting.
2 Regulatory 403100 HNP-10-064 6/9/2010 Providing procedural changes to Engineering Change (EC)
Correspondence address potential spurious valve 67999 was completed to on NFPA-085 12/22/2010 operations identified during the update site procedures non-power operation review is an and fulfill the commitment outstanding item. in the agreed timeframe.
3 Regulatory 403100 HNP-10-064 6/9/2010 Completion of the updates to the Calculation Correspondence appropriate change evaluation in order HNP-M/MECH-1117 was on NFPA-085 12/22/2010 to document that cable 0245B is not completed to fulfill the within the zone of influence of a commitment in the agreed significant ignition source is an timeframe.
outstanding item.
4 Regulatory 460581 HNP-11-001 4/28/2011 Relocated Technical Specifications The Technical Correspondence and Design Basis Requirements Specifications and design on Measurement 6/2/2012 procedure (PLP-1 14) will be revised basis requirements were Uncertainty to include the leading edge flow meter implement in the PLP-114 Recapture Power (LEFM) controls. procedure in the agreed Uprate (MUR) timeframe.
No. Category Action Letter No. Letter Date Commitment Completion Notes Request &
No. Completion Date 5 Regulatory 505508 HNP-11-001 4/28/2011 Procedures and documents for the PLP-106 was updated Correspondence new LEFM will be established or according to the on MUR 5/14/2012 revised. commitment and the agreed timeframe.
Incorporate Technical Specification Task Force (TSTF)-493 values into procedure PLP-106 Technical Specification equipment List Program and Core Operating Limit Report.
6 Regulatory 460581 HNP-11-001 4/28/2011 Appropriate personnel will receive The training was Correspondence training on the LEFM and affected completed before refueling on MUR 4/5/2012 procedures. outage and in the agreed timeframe.
7 Regulatory 137296 HNP-09-011 1/27/2009 HNP will report how it has addressed The commitment is being Correspondence the in-vessel downstream effects tracked in PassPort and on GL 2004-02 Pending issue per the guidance contained in has been given an Completion the NRC letter dated September appropriate due date (ML082540269). consistent with the intent/scope of GL-2004-02.
The NRC staff has not issued the safety evaluation related to the WCAP-16793.
No. Category Action Letter No. Letter Date & Commitment Completion Notes Request Completion No. Date 8 Regulatory 412601 HNP-10-073 July 28, 2010 After implementation of the HNP TS The commitment is being Commitment Amendment approving use of the tracked in PassPort and Associated with Pending thermal-hydraulic analysis has been given an S-RELAP5 LAR Completion methodology EMF-2310 (S-RELAP5) appropriate due date for Chapter 15 non loss-of coolant consistent with the accident (LOCA) transients, intent/scope of the LAR.
EMF-2310 will be used for new replacement safety analysis currently performed using ANF-89-151 methodology.
If it becomes necessary to correct an error in the current ANF-89-151 analyses, ANF-89-151 methodology will be used for the error correction.
9 Regulatory 481777 HNP-11-034 8/16/2011 Capsule Y or Z will be removed at the The commitment is being Commitment end of Cycle 21 and tested per ASTM tracked in the PassPort associated with Pending E-185-82. and has been given an the Schedule Completion appropriate due date Removal of consistent with the Capsule Y or Z intent/scope of the during Refueling HNP-11-034 letter.
Outage -21
No. Category Action Letter No. Letter Date & Commitment Completion Notes Request No. Completion Date 10 Regulatory 518870 HNP-12-023 2/23/2012 CP&L commits to apply a 138 The commitment is being Commitment degree Fahrenheit conservative tracked in the PassPort associated with Pending adder to peak and has been given an the Realistic Large Completion cladding temperatures calculated appropriate due date Break LOCA LAR using the plant-specific methodology consistent with the that implements ARE VA's NRC- intent/scope of the approved topical report EMF-2103 HNP-12-023 letter.
(P) (A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors, Revision 0. The 138 degree Fahrenheit conservative adder will be reflected in reports of peak cladding temperature submitted in accordance with 10 CFR 50.46 (a)(3).
11 Commitment 289326 PE&RAS- 10/6/2008 Removal of the plant-specific TS The commitment was associated to LAR 08-037 requirements will be performed completed before the to Eliminate Work 8/17/2009 concurrently with the implementation agreed upon timeframe.
Hour Controls to of the 10 CFR Part 26, Subpart I Comply with the requirements.
Revised 10 CFR Part 26 12 Commitment 302413 HNP-08099 10/24/2008 Replace temporary non-code repair EC 73305 was associated to the of defect in weld on line implemented to complete Relief Request 5/5/2009 3SW1-267SA-1 with a permanent the repair.
I3R-05 repair. Temporary non-code repair consists of deferral of code repair The commitment was until the scheduled outage completed before the exceeding 30 days but no later than agreed upon timeframe.
the next scheduled refueling outage, provided the condition continues to meet the acceptance criteria of GL 90-05.
No. Category Action Letter No. Letter Date & Commitment Completion Notes Request No. Completion Date 13 Commitment 302413 HNP-08099 10/24/2008 Perform weekly inspections of The operators log associated to the location to detect changes in size or confirmed that the Relief Request Various leakage of weld until code repair is surveillance was I3R-05 performed. The structural integrity completed according to and the monitoring frequency will be the commitment.
re-evaluated if significant changes are found in the condition of the weld area during this monitoring.
14 Commitment 302413 HNP-08099 10/24/2008 Perform ultrasonic measurements of The commitment required associated to the the area where the flaw is located at to perform ultrasonic Relief Request Various least once every 90 days. measurements on I3R-05 5/6/2008, 8/16/2008, 11/18/2008, and 2/4/2009.
The 5/6/2008 and 2/4/2009 ultrasonic measurements were completed according to the commitment.
The 8/16/2008 ultrasonic measurement was completed on 9/22/2008.
The 11/18/2008 ultrasonic measurement was completed on 11/10/2008.
No. Category Action Letter No. Letter Date & Commitment Completion Notes Request No. Completion Date 15 Commitment 319202 HNP-09-016 7/26/2009 HNP has verified, and is making a The commitment was associated with the regulatory commitment to maintain, completed by change TSTF-447 8/19/2009 a hydrogen monitoring system request form #3154 to Elimination of capable of diagnosing beyond update the Final Safety Hydrogen and design-basis accidents. Analysis Report.
Oxygen Monitors The commitment was completed before the agreed upon timeframe and was implemented after the NRC staff issued the safety evaluation related to TSTF-447.
G. Hamrick - 2 Please direct any inquiries to me at 301-415-3302 or via email atAraceli.Billoch@nrc.gov.
Sincerely, IRA!
Araceli T. Billoch Colon, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400
Enclosure:
Audit Report cc w/encl: Distribution via ListServ DISTRIBUTION:
PUBLIC LPL2-2R/F RidsNrrPMShearonHarris RidsNrrLABClayton RidsOgcRp RMusser RidsAcrsAcnwMailCenter RidsRgn2MailCenter SMeighan RidsNrrDorlLpl2-2 JAustin PLessard ADAMS Accession No'.. ML12277A129 OFFICE LPL2-2/PM LPL2-2/LA LPL2-2/BC(A) LPL2-21PM NAME ABillochCol6n BClayton JQuichocho ABiliochCol6n DATE 11/6/12 1116112 11113/12 11/13112 OFFICIAL RECORD COPY