ML12178A028
| ML12178A028 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/29/2012 |
| From: | Tam P S Plant Licensing Branch III |
| To: | Weber L J Indiana Michigan Power Co |
| Tam P S | |
| References | |
| TAC ME7636, TAC ME7637 | |
| Download: ML12178A028 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 29,2012 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 SUBJECT: DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7636 AND ME7637) Dear Mr. Weber: In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the 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. An audit of Donald C. Cook's commitment management program was performed in June 2012, approximately 3 years from the last audit (see letter, T. A. Beltz to J. N. Jensen, August 19, 2009; Accession No. ML092170536). Based on the audit, the NRC staff concludes that (1) the licensee has implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee had implemented an effective program to manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit report. This . completes the NRC staff's efforts on this issue. Peter S. Tam, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316 Enclosure: As stated cc w/encl: Distribution via ListServ UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION DONALD C. COOK NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 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 Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEt 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 whether 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 guidance 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 previous audit was performed 3 years ago (see letter, T. A. Beltz to J. N, Jensen, August 19, 2009; Accession No. ML092170536). Thus this covers the period from approximately mid-2009, to mid-2012. The audit was performed in June 2012. The audit consisted of two major parts: (1) verification of the licensee's implementation of commitments made to NRC that have been completed; and (2) verification of the licensee's program for managing changes to commitments made to the NRC. Enclosure Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has tracked and 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 the bulk of commitments made by the licensee 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, reliefs, etc.) or licensing activities (response to bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation were not included in this audit since those are addressed under the NRC's inspection program. Before the audit, the NRC staff searched the Official Agency Record system for licensee correspondence conveying commitments, and have included in the audit all the commitments thus found (see Table 1). The NRC staff recognizes that "all the commitments" does not equate to "a representative sample"; however, the licensee had not made too many commitments in the subject three-year period for a "representative sample" to be selected. 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. 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 (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. Audit Results The NRC staff reviewed the licensee's site documents Commitment Implementation/Closure Forms generated by the licensee's tracking program for the commitments listed in Table 1 to evaluate the status of completion. 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, and that the licensee had implemented the commitments on a timely basis. Table 1 summarizes what the NRC staff observed as the current status of licensee commitments made in the period since the previous audit was performed.
-3 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 D. C. Cook is set forth in a procedure identified as PMP-2350-CMS-001, "Commitment Management," Revision 4. This procedure makes extensive references to NEI 99-04. In particular, Section 4.4 specifically addresses the process to modify existing commitments. Based on review of this cited document, the NRC staff concludes that the licensee's procedures follow closely the guidance of NEI-99-04 in that it sets forth the need for identifying, tracking, and reporting commitments, and it provides a mechanism for changing commitments. The effectiveness of a procedure can be indicated by the products that are produced by the procedure. As set forth in Section 2.1.1 and Table 1 of this report, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of review of the licensee's information, the NRC staff found no reason to differ from the licensee's reported status of the audited commitments. Thus, the NRC staff surmises that the procedure used by the licensee to manage commitments is appropriate and effective. 3.0 CONCLUSION Based on the above audit, the NRC staff concludes that (1) the licensee has implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee has implemented an effective program to manage regulatory commitment changes. 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Licensee personnel supporting this audit were Helen Etheridge and John Nimtz. Principal Contributor: Peter S. Tam Date: June 29, 2012 TABLE 1 DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 AUDIT OF WRITTEN REGULATORY COMMITMENTS 2009 THROUGH 2012 NSPM Submittal NRC TAC No. NRC Issuance Summary of commitment Licensee Implementation Status Letter 3/2911 0 ME1147 RAI (for Unit 2 onIY),9/22/09 The licensee will submit a revised small-break LOCA analysis resolving the Completed on 811112011. Tracked ML09261 0017 Residual Heat Removal (RHR) flow under Commitment No. 2010-30 (No other NRC diversion issue by 8/12111 [Submitted on 8/11/2011, AEP-NRC-2011-52, Accession 8509. ML 100960423 issuance needed) No. ML 11235A765.] The licensee will submit a revised small-break LOCA analysis for Unit 1 resolving the RHR flow diversion issue by 8/31/2012. After submittal of the Unit 2 revised small-break LOCA analysis, the licensee will coordinate with the NRC staff to establish which of the questions in the 9/22/09 RAI remain applicable and establish a schedule to respond. Tracked under Commitment No 8511 Eliminated (see publicly available e-mail dated 10/17/2011, Accession No. ML 112901387). Tracked under Commitment No 8512. Letter 7/19/10 ME4275 Amend. 315 (Unit By 6/30/11, train and qualify Cyber Completed 21712011. ME4276 1) and 299 (Unit 2), Security Assessment Team, identify critical Tracked under 7/28/11 systems and digital assets, develop cyber Commitment No. 8516. 2010-49 security defense strategy. ML102080349 By 6/30/12, implement defense-in-depth architecture for isolation boundaries By 6/30/13, implement cyber security defense-in-depth architecture for all other non-isolation boundaries. By 12/31/13, establish cyber security program policies/procedures, perform and document the cyber security assessment described in the Cyber Security Plan. By 48 months after NRC approval of the Cyber Security Plan, implement security controls not requiring plant modification, implement Cyber Security Program and enter into maintenance phase. Tracked under Commitment No. 8519 Tracked under Commitment No. 8520 Tracked under Commitment No. 8521 and 8522 Tracked under Commitment No. 8523 and 8524 Letter 4/8/11 ME4275 ME4276 Amendment 215 (Unit 1) and 299 By December 31,2012, the security control "Access Control For Portable And Mobile Ongoing. Tracked under Commitment No. (Unit 2), 7/28/11 Devices" described in Appendix D 1.19 of 8533. 2011-18 NEI 08-09, Revision 6, will be implemented. ML11111A058 By December 31, 2012, implement observation and identification of obvious cyber related tampering to existing insider Ongoing. Tracked under Commitment 8534. Attachment
-2 mitigation rounds by incorporating the appropriate elements in Appendix E Section 4.3 "Personnel Performing Maintenance And Testing Activities." By December 31,2012, identify, document, and implement cyber security controls in accordance with the Cyber Security Plan Section 3.1.6 "Mitigation of Vulnerabilities and Application of Cyber Security Controls" for critical digital assets that could adversely impact the design function of physical security target set equipment. Completed. Tracked under Commitment No. 8535. Letter (for Unit ME7722 Amendment and Confirm that Westinghouse will continue to Ongoing. Tracked 2 only) 9/29/11 ME7323 exemption to be issued. provide additional data from the Optimized ZIRLOŽ lead test assembly programs to under Commitment No. 8527. the NRC after new data for higher 2011-56 burnup/fluence become available. Confirm that as higher burnups/fluences are ML 11286A198 achieved for Optimized ZIRLOŽ clad fuel rods that the requirements of this condition will be met as it applies to Unit 2. This commitment relates to conditions and limitations 6 of the NRC Safety Evaluation for Optimized ZIRLOTM. This commitment continues for each cycle-specific core reload safety evaluation until the lead test assembly data up through the fuel burnup limit applicable for Cook Unit 2 has been provided to the NRC. Letter (for Unit ME7722 Amendment and Confirm that as higher burnupslfluences Ongoing. Tracked 2 only) 9/29/11 ME7323 exemption to be issued. are achieved for Optimized ZIRLOŽ clad fuel rods that the requirements of this under Commitment 8528. condition will be met as it applies to Cook 2011-56 Unit 2. This evaluation relates to conditions and limitations 7 and 8 of the ML 11286A198 NRC SE for Optimized ZIRLOTM. This commitment continues for each cycle-specific core reload safety evaluation until the contingency requirements of the conditions and limitations have been satisfied. Letter, 3/11/11 ME1017 Unit 2 Amend. No. The licensee committed to perform an Complete. Tracked 297 updated analysis of the potential for boric under Commitment No. (3/31/2011) acid precipitation to occur during the 8530. 2011-21 recirculation phase of a postulated Large-break loss-of-coolant accident, and ML 110810103 transmit a summary of the analysis to the NRC no later than June 30, 2011. The letter was submitted and dated 6/30/2011 (Accession No. ML 11193A04 7) Letter, 3/19/09 ME1012 Amend. 310 and Before 10/1/2009, remove plant-specific Completed 10/1/2009. ME1013 292,7/24/2009 Technical Specification requirements (ML091470163) concurrently with the implementation of the Tracked under 2009-18 10 CFR Part 26, Subpart I requirements. Commitment No. 8481. ML090920411
-Letter, 9/8/10 ME4709 Amend. 313 (Unit By the date the proposed amendment is Completed 4/6/2011. ME4710 1) and 296 (Unit 2), implemented (Le., 120 days after 12/14/10 Tracked under 12/14/10 =4113111), the licensee will maintain a Commitment No. 8525. 2010-58 hydrogen monitoring system capable of ML 102590353 diagnosing beyond design-basis accidents at Units 1 and 2. The hydrogen monitor system will be included in the units' Technical Requirements Manuals. Letter 10/8/10 None. The following enhancements to the Structures Monitoring Program will be Ongoing. Tracked under Commitment No. implemented prior to the period of 8263 (for the 2010-61 extended operation: Include the following in the Structures Monitoring Program: commitment under Structures Monitoring ML102930151
- ramp curbs at the turbine room entrance to passageway between the diesel generator rooms,
- the reinforced concrete grade beam wall and tops of the ramps on the west side of the Turbine Building. The following enhancements will be made to the Preventive Maintenance (PM) Program: The Preventive Maintenance Program will manage the aging effects of the following components:
- hatch over the flapper valve and hold down bolts,
- rubber flex hoses and fittings in the back up air supply for the Essential Service Water strainer backwash valves. Program) Ongoing, tracked under Commitment No. 8257 (for the commitment under Preventive Maintenance Program) Letter (for Unit ME5183 Amend. 316, Confirm that Westinghouse will continue to Ongoing. Tracked 1 only), ME5184 8/25/2011 provide additional data from the Optimized under Commitment No. 12/16/2010 (ML 111610020) ZIRLO Ž lead test assembly programs to the NRC after new data for higher 8527. AEP-NRC-Exemption. burnuplfluence become available. Confirm 2010-51 8/24/2011 (ML 11209C033) that as higher burnups/fluences are achieved for Optimized ZIRLOŽ clad fuel ML1 03630358 rods that the requirements of this condition will be met as it applies to Unit 1. This commitment relates to conditions and limitations 6 of the NRC Safety Evaluation for Optimized ZIRLOTM. Letter (for Unit ME5183 Amend. 316, Confirm that as higher burnups/fluences Ongoing. Tracked 1 only), ME5184 8/25/2011 are achieved for Optimized ZIRLOŽ clad under Commitment No. 12116/2010 (ML 111610020) fuel rods that the requirements of this condition will be met as it applies to Unit 1. 8528. AEP-NRC-Exemption, This evaluation relates to conditions and 2010-51 8/24/2011 (ML 11209C033) limitations 7 and 8 of the NRC SE for Optimized ZIRLOTM. ML 103630358 June 29, 2012 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7636 AND ME7637) Dear Mr. Weber: In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the 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. An audit of Donald C. Cook's commitment management program was performed in June 2012, approximately 3 years from the last audit (see letter, T. A. Beltz to J. N. Jensen, August 19, 2009; Accession No. ML092170536). Based on the audit, the NRC staff concludes that (1) the licensee has implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee had implemented an effective program to manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit report. This completes the NRC staff's efforts on this issue. Sincerely, IRA! Peter S. Tam, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316 Enclosure: As stated cc w/encl: Distribution via ListServ DISTRIBUTION: PUBLIC LPL3-1 r/f RidsNrrDorlLpl3-1 Resource RidsNrrPMDCCookResource RidsNrr RidsNrrLABTully Resource RidsRgn3MailCenter Resource RidsAcrsAcnw_MailCTR Resource RidsOgcRp Resource SMeighan, NRR PLaflamme, RGN-III JGiessner, RGN-III ADAMS ACCESSION NUMBER' ML 12178A028 OFFICE LPL3-1/PM LPL3-1/LA LPL3-1/BC(A) LPL3-1/PM NAME PTam BTuily IFrankl PTam DATE 6/28/12 6/27112 6/29/12 6/28/12 OFFICIAL RECORD COpy