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| number = ML113570110 | | number = ML113570110 | ||
| issue date = 01/17/2012 | | issue date = 01/17/2012 | ||
| title = Audit of | | title = Audit of Licensees Management of Regulatory Commitments, Audit Performed October 18-21, 2011 | ||
| author name = Wang A | | author name = Wang A | ||
| author affiliation = NRC/NRR/DORL/LPLIV | | author affiliation = NRC/NRR/DORL/LPLIV | ||
| Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 17, 2012 Mr. John T. Conway Senior Vice President - Energy Supply and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant 77 Beale Street, Mail Code B32 San Francisco, CA 94105 | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 17, 2012 Mr. John T. Conway Senior Vice President - Energy Supply and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant 77 Beale Street, Mail Code B32 San Francisco, CA 94105 | ||
==SUBJECT:== | ==SUBJECT:== | ||
DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7284 AND ME7285) | DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7284 AND ME7285) | ||
==Dear Mr. Conway:== | ==Dear Mr. Conway:== | ||
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the 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. | In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the 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 that the regulatory commitments are being effectively implemented. | 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 the regulatory commitments are being effectively implemented. | ||
An audit of the Diablo Canyon Power Plant, Units 1 and 2, commitment management program was performed at the plant site during the period October 18-21, 2011. Based on the audit, the NRC staff concludes that Pacific Gas and Electric Company (the licensee) has implemented NRC commitments on a timely basis, and has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report. | An audit of the Diablo Canyon Power Plant, Units 1 and 2, commitment management program was performed at the plant site during the period October 18-21, 2011. Based on the audit, the NRC staff concludes that Pacific Gas and Electric Company (the licensee) has implemented NRC commitments on a timely basis, and has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report. | ||
J. Conway | J. Conway | ||
Sincerely, AI~n~r:c.ger Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323 | -2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov. | ||
Sincerely, AI~n~r:c.ger Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323 | |||
==Enclosure:== | ==Enclosure:== | ||
Audit Report cc w/encl: Distribution via Listserv | |||
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323 | |||
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323 | |||
==1.0 INTRODUCTION AND BACKGROUND== | |||
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS) | In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS) | ||
Accession No. ML003741774), the 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 enSIJre that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. | Accession No. ML003741774), the 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 enSIJre that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. | ||
| Line 45: | Line 43: | ||
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. | 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. relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years. | 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. relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years. | ||
2.0 | 2.0 AUDIT PROCEDURE AND RESULTS An audit of the Diablo Canyon Power Plant, Units 1 and 2 (DCPP), commitment management program was performed at the plant site during the period October 18-21, 2011, and discussed during a teleconference on November 10, 2010, with members of the Pacific Gas and Electric Company (PG&E, the licensee) staff. The audit reviewed commitments made by the licensee Enclosure | ||
- 2 since the previous audit on September 17-18, 2008, which was documented in an audit report dated October 22, 2008 (ADAMS Accession No. Ml082800342). 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 | 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. | ||
2.1.1 | 2.1.1 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, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in 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: | The audit excluded the following types of commitments that are internal to licensee processes: | ||
(1) | (1) | ||
(2) | 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). | 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. | Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed. | ||
(3) | (3) | ||
2.1.2 | 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. | ||
For reference, the licensee's "recurring task" commitments are tracked in the computer-based Procedure Commitment Database (PCD) while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand alone spreadsheet). The licensee's commitments are managed in accordance with DCPP administrative procedure XI4.ID1, "Commitment Identification and Tracking Process," | 2.1.2 Audit Results The attached Audit Summary -Implementation of Commitments (Attachment 1) provides details of the audit and its results. | ||
For reference, the licensee's "recurring task" commitments are tracked in the computer-based Procedure Commitment Database (PCD) while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand alone spreadsheet). The licensee's commitments are managed in accordance with DCPP administrative procedure XI4.ID1, "Commitment Identification and Tracking Process," | |||
- 3 Revision 6A. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory 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 as required by DCPP. The NRC staff reviewed relevant reports and summary sheets from the computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition. the NRC staff reviewed two licensee self assessments of its "NRC Commitment Management" in the "2009 Technical Specification and Testing Audit" dated October 23,2009, and the "2011 Technical Specification Audit" dated October 5, 2011. | |||
Based on the review of reports provided by the licensee as described above and on queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis (as documented in Attachment 1). | Based on the review of reports provided by the licensee as described above and on queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis (as documented in Attachment 1). | ||
2.2 | 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 the DCPP is contained in administrative procedure XI4.ID2, "Commitment Change Process," Revision 9 with accompanying change form DCPP 69-20200, "Commitment Change Request" dated April 12, 2010. The auditors 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 auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's 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. | The auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's 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 | 2.2.1 Audit Results The attached Audit Summary - Management of Changes to Regulatory Commitments (Attachment 2) provides details of this portion of the audit and its results. | ||
The NRC staff reviewed procedure X14.ID2 and its required form to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation. | The NRC staff reviewed procedure X14.ID2 and its required form to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation. | ||
The NRC staff compared the guidance in the DCPP administrative procedure X14.ID2 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the DCPP procedure was consistent with the NEI guidance for identifying, managing, and closing | The NRC staff compared the guidance in the DCPP administrative procedure X14.ID2 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the DCPP procedure was consistent with the NEI guidance for identifying, managing, and closing | ||
-4 commitments and that the roles and responsibilities, processes, and metrics were clearly identified in the DCPP procedure with the following programmatic exceptions: | |||
(1) | (1) | ||
The NRC staff reviewed procedure X14.ID1 and noted in step 3.6.2 that "the following types of commitments are maintained by their respective departments: | |||
: a. Security Program Commitments, b. Training Program Commitments." NRC staff interviews with licensee Security and Training (Learning Services) personnel revealed that neither department had established a commitment tracking or management program either formally or informally. Neither department had created commitment management procedures, nor did they have a list or mechanism to centrally track known and existing departmental commitments. | : a. Security Program Commitments, b. Training Program Commitments." NRC staff interviews with licensee Security and Training (Learning Services) personnel revealed that neither department had established a commitment tracking or management program either formally or informally. Neither department had created commitment management procedures, nor did they have a list or mechanism to centrally track known and existing departmental commitments. | ||
Additionally, in Action Request (AR) A0641 042, dated June 25,2005, Learning Services specifically stated that "the ability to embed the PCD entry into Training procedures is a very important tool for use by learning services" and that "the use of PCD to register commitments from federal, state, ... , is a keystone to the rigor." In this AR, Regulatory Services discussed the use of a new process (nexis) to "improve capabilities ... for management of commitments in RS | Additionally, in Action Request (AR) A0641 042, dated June 25,2005, Learning Services specifically stated that "the ability to embed the PCD entry into Training procedures is a very important tool for use by learning services" and that "the use of PCD to register commitments from federal, state,..., is a keystone to the rigor." In this AR, Regulatory Services discussed the use of a new process (nexis) to "improve capabilities... for management of commitments in RS | ||
[regulatory services], LS [learning services], and security." This AR was closed based on the eventual arrival of the new process and the commitment to continue manual tracking of Learning Services commitments. | [regulatory services], LS [learning services], and security." This AR was closed based on the eventual arrival of the new process and the commitment to continue manual tracking of Learning Services commitments. | ||
Based on the above review, the NRC staff identified that this commitment management program gap for Security and Learning Services was originally identified by the licensee as early as June 2005, was discussed generally as item 2.5.(b) in the previous NRC commitment audit report, and was not corrected by the time of this audit with the new process in place. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435195 to address this issue. | Based on the above review, the NRC staff identified that this commitment management program gap for Security and Learning Services was originally identified by the licensee as early as June 2005, was discussed generally as item 2.5.(b) in the previous NRC commitment audit report, and was not corrected by the time of this audit with the new process in place. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435195 to address this issue. | ||
(2) | (2) | ||
Further NRC staff interviews with the licensee's personnel revealed that should there be a change required to a "single task" commitment, then the review process for modification of a corrective action program corrective action would evaluate the change. Following a review of modified "single task" commitments, the NRC staff identified that the NEI 99-04 flowchart guidance within | The NRC staff review of XI4.ID1, "Commitment Identification and Tracking Process" revealed that only "recurring task" commitments are entered into the PCD while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand-alone spreadsheet). X14.ID1 states in step 3.2.1 that a single task commitment is "a commitment type that can be resolved and implemented by a one time action that does not require a controlled process to ensure its continued and consistent implementation." NRC staff interviews with the licensee's personnel revealed that while there is not an explicit prohibition to using XI4.ID2, "Commitment Change Process" with its change management flowchart for "single task" commitments, site practice and procedural intent is to utilize X14.ID2 for PCD entered "recurring task" commitments only. | ||
Further NRC staff interviews with the licensee's personnel revealed that should there be a change required to a "single task" commitment, then the review process for modification of a corrective action program corrective action would evaluate the change. Following a review of modified "single task" commitments, the NRC staff identified that the NEI 99-04 flowchart guidance within | |||
-5 of X14.ID2 and Form DCP 69-20200 were not being utilized to evaluate the notification or evaluation needed for this commitment change. below provides specific examples of this issue with recent "single task" commitments. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435196 to address this issue. | |||
Based on the review of the reports provided by the licensee as described above, queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes is in accordance with its site procedure with the programmatic deficiencies noted above in the examples documented in Attachment 2. | |||
Based on the review of the reports provided by the licensee as described above, queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes is in accordance with its site procedure with the programmatic deficiencies noted above in the examples documented in Attachment 2. | |||
==3.0 CONCLUSION== | |||
Based on the audit, the NRC staff concludes that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. | Based on the audit, the NRC staff concludes that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. | ||
4.0 | 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Steven Zawalick Corrado Sansone Mark Padovan Philippe Soenen Principal Contributor: James T. Polickoski Date: January 17, 2012 Attachments: | ||
: 1. Audit Summary - Implementation of Commitments | : 1. Audit Summary - Implementation of Commitments | ||
: 2. Audit Summary - Management of Changes to Regulatory Commitments | : 2. Audit Summary - Management of Changes to Regulatory Commitments | ||
ATTACHMENT 1 AUDIT | ATTACHMENT 1 AUDIT | ||
==SUMMARY== | ==SUMMARY== | ||
. IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21! 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 | |||
AUDIT | AUDIT | ||
==SUMMARY== | ==SUMMARY== | ||
- IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT. UNITS 1 AND 2 Commitment Source | - IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT. UNITS 1 AND 2 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status Gl DCl-11-035 3/17/2011 Supplement to Response to Nuclear Regulatory Commission (NRC) Generic letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" No explicit | ||
: number, tracked as a "one-time commitment" per XI4.ID1. | |||
Pacific Gas and Electric Company (PG&E) will perform an ultrasonic test (UT) inspection at this local high point to inspect for gas accumulation following the dynamic venting of the residual heat removal (RHR) heat exchangers coming out of Unit 2 Refueling Outage Sixteen (2R16) and Unit 2 Refueling Outage Seventeen (2R17). | |||
Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" th | Notification 50037662 CLOSED - Commitment completed for 2R16 as described. | ||
Gl DCl-08-090 10/14/2008 Nine-Month Response to NRC Generic letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" The 16 th commitment in the PG&E letter but has no programmatic number since tracked as a "one-time commitment" per X14.1D1. | |||
PG&E will require that dynamic venting be performed for 10/1112009 each unit to flush out any gas from the RHR heat exchanger after each reactor coolant system (RCS) vacuum refill operation by 10/11/2009. | |||
Notification 50037662 CLOSED - Commitment closed as a "recurring task" commitment to T36602 and is implemented in Operating Procedure (OP) 8-2:XI. | |||
-2 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status Bl Bl2007-01 DCL-08-011 21712008 Physical Security Plan Change No explicit number. It is a Security commitment with no current Implement a Physical Security Plan change to perform training In Security Department procedure SP 210. | |||
NCR 60025143 NCR 60027840 CLOSED - Commitment implemented in the Physical Security Plan training procedure as a document reference. As Security commitments are not tracked in the tracking system. It would be classified as a Procedure Commitment Database (PCD), the training procedure is the only reference for its completion. | |||
Other DCl-05-058 5/25/2005 | "recurring task" commitment per XI4.ID1. | ||
accordance with Title 10 of the Code ECG 18.2 of Federal Regulations Section 2.390 (10 CFR 2.390). | CLOSED - Commitment closed and implemented via STP M-67B-1. | ||
Other DCL-07-001 1/11/2007 | Other DCl-05-058 5/25/2005 B5b 1.16 Commitment that is security related and withheld from public disclosure in accordance with Title 10 of the Code STP M-67 ECG 18.2 of Federal Regulations Section 2.390 (10 CFR 2.390). | ||
Other DCl-07-051 5/8/2007 | Other DCL-07-001 1/11/2007 B5b 1.30 Commitment that is security related and withheld from public disclosure in accordance with 10 CFR 2.390. | ||
Notification 50382443 EP MT-21 CLOSED - Commitment closed and implemented via Notification 50382443, Tasks 2 and 3 to include verification of equipment in its location. | |||
Other DCl-07-051 5/8/2007 B5b 2.60 Commitment that is security related and withheld from public disclosure in accordance with 10 CFR 2.390. | |||
CP M-6 FTFT 001 FTFTD 009 CLOSED - Commitment closed and implemented via CP M-6 and Notification 50399546 Task 11 with training held over the last 4 years. | |||
Notification 50399546 LAR DCl-09-009 4/24/2009 Revision to Technical Specification (TS) 3.3.1 No explicit | |||
: number, tracked as a "one-time commitment" per XI4.ID1. | |||
PG&E will use the NRC-approved methodology in Westinghouse WCAP-11394-P-A for each fuel cycle to ensure the minimum departure from nucleate boiling ratio (DNBR) is maintained above the DNBR safety limit. | |||
Notification 50200784 CLOSED - Commitment closed and implemented in the design of both cores in previous cycles and in Notification 50200784, Task 7. | |||
- 3 Type LAR LAR Commitment Source Document DCl-09-032 DCl09-065 Commitment Date 5/5/2009 9/8/2009 Commitment Commitment Subject Number 10 CFR Part No explicit 26 TS changes number, per TSTF-511 tracked as a "one-time commitment" per XI4.ID1. | |||
Emergency No explicit Amendment | |||
Commitment Source | : number, Request to tracked as a revise TS 3.7.1 "one-time commitment" per XI4.ID1. | ||
Description of Commitment PG&E will perform removal of the plant-specific TS requirements concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements. This commitment will be completed no later than 10/112009. | |||
PG&E will calculate the required as-found and as-left tolerances in accordance with the guidance of Regulatory Issue Summary (RIS) 2006-17 prior to the adjustment of the Diablo Canyon Power Plant (DCPP) Unit 2 Maximum Allowable Power Range Neutron Flux High Setpoint from 87 percent to 106 percent during DCPP Unit 2 Cycle 15. | |||
Supporting Documents Notification 50043129 License Amendment 205 and 206 Notification 50265286 license Amendment 208 Calculation J 154 STP 1-37 N41.AlB Implementation Status CLOSED - Commitment closed and implemented via TS implementation on 10/1/2009 as noted in Notification 50043129. | |||
CLOSED - Commitment closed and implemented in STP 1-37-N41A1B 44A1B, ECG 38.3, and Notification 50265286. | |||
STP 1-37 N44.AlB ECG 38.3 Order 60019185-00101 002010030/0040 RIS 2006-17 LAR DCl-10-018 2/24/2010 Revision to TS 3.8.1 No explicit | |||
: number, tracked as a "one-time commitment" per X14.1D1. | |||
PG&E will provide additional guidance to operators in the surveillance procedures as part of implementation of the license amendment request to provide guidance to the operators on use of the new Note added to Surveillance Requirement (SR) 3.8.1.10 and SR 3.8.1.14. | |||
TSTF-493 Rev 4 Notification 50232181 CLOSED Commitment deleted as DCl-10-018 was withdrawn voluntarily by the licensee as noted in Notification 50232181, Task 9. | |||
AITACHMENT 2 AUDIT | AITACHMENT 2 AUDIT | ||
==SUMMARY== | ==SUMMARY== | ||
- MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 | - MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 | ||
AUDIT | AUDIT | ||
==SUMMARY== | ==SUMMARY== | ||
- MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 | - MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 Type GL Commitment Source Document DCL-10-014 DCL-11-035 Commitment Date 2/9/2010 3/17/2011 Commitment Subject Response to Nuclear Regulatory Commission (NRC) Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Commitment Number No explicit | ||
: number, tracked as a "one-time commitment" per XI4.ID1. | |||
Commitment Source | Original Description of Commitment Pacific Gas and Electric Company (PG&E) will install a vent at this high point on the residual heat removal (RHR) pump line during Unit 2 refueling outage sixteen (2R16). | ||
Revised Commitment PG&E will install a vent at this high point on the RHR line during Unit 2 Refueling Outage Eighteen (2R 18). | |||
Supporting Documents DCL-11-035 Change Status DISCREPANCIES NOTED - X14.ID1 does not provide a mechanism for a "single task" or "one time" commitment to enter XI4.ID2. | |||
Therefore, and DCPP Form 69-20200 of X14.ID2 was not utilized as required by the Nuclear Energy Institute (NEI) 99-04 guidance to evaluate the notification or evaluation needed for this commitment change. No safety significance noted. | |||
- 2 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status Gl DCl-08-090 10/14/2008 Nine-Month The 4th PG&E will replace air The Unit 2 valves were Notification DISCREPANCIES Response to commitment operated valves in the replaced as delineated. | |||
50037662 NOTED - XI4.1D1 NRC Generic in the PG&E safety-injection (SI) test For unit 1 during 1 R16, does not provide a letter 2008-01, | |||
Commitment Source | letter but has lines 2R15 with manual only the air-operated mechanism for a "Managing Gas no valves. An additional valves were replaced (10 | ||
Core Cooling, | 'single task" or 'one-Accumulation in programmatic valve will also be added of the originally discussed time" commitment to Emergency number since 1R16 in series in each test 19 valves). | ||
enter X14.1D2. | |||
Core Cooling, tracked as a loop. These changes will Therefore, Decay Heat "one-time provide a more reliable and Removal, and commitment" isolation for test lines, Diablo Canyon Power Containment per X14.1D1. | |||
decreasing the probability Plant (DCPP) Form Spray Systems" of intersystem leakage 69-20200 of X14.ID2 which could result in gas was not utilized as intrusion. These required by the NEI modifications will be 99-04 guidance to performed during 2R 15 evaluate the and 1R16. | |||
notification or evaluation needed for this commitment change. The licensee provided an engineering evaluation in the Notification and did call the NRC project manager (PM). | |||
No safety significance noted. | No safety significance noted. | ||
LAR | LAR DCl-89-320 12121/1989 "Diablo Canyon None Mode Transition Checklists The commitment remained DCl-89-320 Form 69-20200 Units 1 and 2 provided were revised due to the same with the submitted and Additional provisions in Technical exception of the TS approved with no Information and Specification (TS) 3.0.4 reference for TS 3.0.4.b discrepancies noted. | ||
Certification | Certification with review by the Plant only regarding Staff Review Committee. | ||
License Amendment Request 88-05, revision of Technical Specification (TS) Sections 3.0 and 4.0 | License Amendment Request 88-05, revision of Technical Specification (TS) Sections 3.0 and 4.0 | ||
'Applicability' and Associated Bases (generic letter 87-09)" | |||
______ L______ | ______ L______ | ||
- 3 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Status BL DCL-03-008 DCL-03-151 1/31/2003 11/18/2003 Leakage From Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity" None provided. | |||
Bare metal inspection of reactor pressure vessel bottom heads. | |||
and | Deleted due to updated ASME Code case N-722 ASME Section XI Code Case N-722 (73 FR 52730; 9/10/2008). | ||
Form 69-20200 submitted and approved with no discrepancies noted. | |||
LAR DCL-81-302 3/2/1981 Containment recirculation sump and RHR pump suction piping debris inspection T04781 The inspection of the containment recirculation sump and RHR pump suction piping to Valves 8982A an 8982B {shall be} | |||
containment recirculation | conducted by representatives of the engineering department and verified by personnel with knowledge equal to that of the performer. The containment recirculation sump, the sump trash racks, screens, and RHR pump suction lines {shall be} inspected for debris. | ||
Any debris {shall be} | |||
removed from containment and recorded on the inspection sheet. This inspection {shall be} | |||
conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages. | |||
The inspection of the containment recirculation sump and RHR pump suction piping to Valves 8982A an 8982B {shall be} | |||
conducted by representatives of the engineering department and verified by personnel with knowledge equal to that of the performer. | |||
Sump plenum internals and RHR pump suction lines to Valves 8982A and 8982B will only be inspected if a plenum hatch seal is broken or if an initiating event as defined in Surveillance Test Procedure STP M 45A has occurred. Any debris {shall be} removed from containment and recorded on the inspection sheet. This inspection | |||
{shall be} conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages. | |||
Notification 0002152 DCP C-49S57 Form 69-20200 submitted and approved with no discrepancies noted. | |||
- 4 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Status LER LER 2-87 10/1212000 Accumulator T36157 As a result of Accumulator Revise the operations ONCR DC2 Form 69-20200 023-02 (Procedure Commitment Nozzle cracking Nozzle Cracking found in the early 1990s, monthly inspection procedures to examine all 91-TN-N075 submitted and approved with no DCl93-266 Database (PCD) update date) | |||
(PCD) update | Nonconformance Report (NCR) DC2-91-TN-N075 CAPR #3 stated, "Revise the weekly containment inspection rounds sheets to examine all accessible nozzles and underskirt piping for evidence of boric acid crystals which could indicate a through-wall crack. | ||
piping for evidence of boric acid crystals which could indicate a through-wall crack. | accessible accumulator nozzles and underskirt piping for evidence of boric acid crystals that could indicate through wall cracks. | ||
lER | OP1.DC3 Notification | ||
: 50375715, 50375714 STP 1-1F discrepancies noted. | |||
Maintenance procedure | Licensee noted and corrected in 2000 that the original commitment was not properly logged in PCD. | ||
lER NRC Inspection Report 50 275192-17 and 50 323/92-17. | |||
Non conformance report N001627 (NCR DCO 92-MM-N007) | |||
DCl92-068 lER 1-91 019-00 DCl-92-134 lER 1-91 019-01 DCl-92-161 7/911992 PCD update 1111112003 07/30/1992 PCD update 11/1112003 Containment Fan Cooler Unit (CFCU) | |||
Backdraft Dampers Backdraft Damper Maintenance T34927 T34928 The CFCU Surveillance Test Procedure (was) revised to specifically verify backdraft damper operability (DCl 92-(68). | |||
STP M-93a, "CFCU Test," | |||
for backdraft dampers will be revised to adequately verify backdraft damper operability following CFCU maintenance (DCl92-161). The post-maintenance testing procedure (was) revised to include steps to backdraft damper critical safety function. Procedures (were) developed for backdraft damper maintenance with appropriate QC hold pOints (DCl 92-068). | |||
Maintenance procedure (MP) M-23.8 is being developed to provide more specific instructions for CFCU backdraft damper maintenance (DCl92-161). | |||
DELETE - No commitments remain for the Unit 2 backdraft dampers. | |||
STP M-93A MP M-23.8 DCP 1000000119 DCP 1000000108 Form 69-20200 submitted and approved with no discrepancies noted. | |||
J. Conway | J. Conway | ||
- 2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov. | |||
Docket Nos. 50-275 and 50-323 | |||
==Enclosure:== | ==Enclosure:== | ||
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION: | Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION: | ||
PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMDiabloCanyon Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JPolickoski, NRRIDORLlLPL4 ADAMS Accession No. ML113570110 OFFICE | PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMDiabloCanyon Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JPolickoski, NRRIDORLlLPL4 ADAMS Accession No. ML113570110 Sincerely, IRA! | ||
Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation OFFICE NRR/LPL4/PM NRR/LPL4/PM 4/LA NRR/LPL4/BC NRR/LPL4/PM NAME JPolickoski AWang JBurkhardt MMarkley AWang TE 12/22/11 1/9/12 1/5/12 1/17/12 1/17/12 OFFICIAL RECORD COpy}} | |||
Latest revision as of 21:21, 12 January 2025
| ML113570110 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/17/2012 |
| From: | Wang A Plant Licensing Branch IV |
| To: | Conway J Pacific Gas & Electric Co |
| Polickoski J, NRR/DORL/LPL4, 415-5430 | |
| References | |
| TAC ME7284, TAC ME7285 | |
| Download: ML113570110 (17) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 17, 2012 Mr. John T. Conway Senior Vice President - Energy Supply and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant 77 Beale Street, Mail Code B32 San Francisco, CA 94105
SUBJECT:
DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME7284 AND ME7285)
Dear Mr. Conway:
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the 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 that the regulatory commitments are being effectively implemented.
An audit of the Diablo Canyon Power Plant, Units 1 and 2, commitment management program was performed at the plant site during the period October 18-21, 2011. Based on the audit, the NRC staff concludes that Pacific Gas and Electric Company (the licensee) has implemented NRC commitments on a timely basis, and has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted. The details of the results of the audit are set forth in the enclosed audit report.
J. Conway
-2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.
Sincerely, AI~n~r:c.ger Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosure:
Audit Report cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323
1.0 INTRODUCTION AND BACKGROUND
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML003741774), the 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 enSIJre 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 the 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. relief requests, 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 Diablo Canyon Power Plant, Units 1 and 2 (DCPP), commitment management program was performed at the plant site during the period October 18-21, 2011, and discussed during a teleconference on November 10, 2010, with members of the Pacific Gas and Electric Company (PG&E, the licensee) staff. The audit reviewed commitments made by the licensee Enclosure
- 2 since the previous audit on September 17-18, 2008, which was documented in an audit report dated October 22, 2008 (ADAMS Accession No. Ml082800342). 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.
2.1.1 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, relief requests, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in 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:
(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, 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 -Implementation of Commitments (Attachment 1) provides details of the audit and its results.
For reference, the licensee's "recurring task" commitments are tracked in the computer-based Procedure Commitment Database (PCD) while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand alone spreadsheet). The licensee's commitments are managed in accordance with DCPP administrative procedure XI4.ID1, "Commitment Identification and Tracking Process,"
- 3 Revision 6A. For this audit, the NRC staff reviewed the selected sample of open and closed regulatory 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 as required by DCPP. The NRC staff reviewed relevant reports and summary sheets from the computer database and other sources (e.g., corrective action documentation, plant procedures, job numbers, documented training, etc.) providing the status of each commitment, form of implementation, and any pending further action. In addition. the NRC staff reviewed two licensee self assessments of its "NRC Commitment Management" in the "2009 Technical Specification and Testing Audit" dated October 23,2009, and the "2011 Technical Specification Audit" dated October 5, 2011.
Based on the review of reports provided by the licensee as described above and on queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet during the audit, the NRC staff found that the licensee has generally implemented commitments on a timely basis (as documented in Attachment 1).
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 the DCPP is contained in administrative procedure XI4.ID2, "Commitment Change Process," Revision 9 with accompanying change form DCPP 69-20200, "Commitment Change Request" dated April 12, 2010. The auditors 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 auditors also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's 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 The attached Audit Summary - Management of Changes to Regulatory Commitments (Attachment 2) provides details of this portion of the audit and its results.
The NRC staff reviewed procedure X14.ID2 and its required form to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed relevant reports and summary sheets from the computer database and other sources providing the status of each commitment, tracking and change forms, and other associated documentation.
The NRC staff compared the guidance in the DCPP administrative procedure X14.ID2 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the DCPP procedure was consistent with the NEI guidance for identifying, managing, and closing
-4 commitments and that the roles and responsibilities, processes, and metrics were clearly identified in the DCPP procedure with the following programmatic exceptions:
(1)
The NRC staff reviewed procedure X14.ID1 and noted in step 3.6.2 that "the following types of commitments are maintained by their respective departments:
- a. Security Program Commitments, b. Training Program Commitments." NRC staff interviews with licensee Security and Training (Learning Services) personnel revealed that neither department had established a commitment tracking or management program either formally or informally. Neither department had created commitment management procedures, nor did they have a list or mechanism to centrally track known and existing departmental commitments.
Additionally, in Action Request (AR) A0641 042, dated June 25,2005, Learning Services specifically stated that "the ability to embed the PCD entry into Training procedures is a very important tool for use by learning services" and that "the use of PCD to register commitments from federal, state,..., is a keystone to the rigor." In this AR, Regulatory Services discussed the use of a new process (nexis) to "improve capabilities... for management of commitments in RS
[regulatory services], LS [learning services], and security." This AR was closed based on the eventual arrival of the new process and the commitment to continue manual tracking of Learning Services commitments.
Based on the above review, the NRC staff identified that this commitment management program gap for Security and Learning Services was originally identified by the licensee as early as June 2005, was discussed generally as item 2.5.(b) in the previous NRC commitment audit report, and was not corrected by the time of this audit with the new process in place. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435195 to address this issue.
(2)
The NRC staff review of XI4.ID1, "Commitment Identification and Tracking Process" revealed that only "recurring task" commitments are entered into the PCD while "single task" commitments are tracked elsewhere (most typically in the corrective action program and in a regulatory services stand-alone spreadsheet). X14.ID1 states in step 3.2.1 that a single task commitment is "a commitment type that can be resolved and implemented by a one time action that does not require a controlled process to ensure its continued and consistent implementation." NRC staff interviews with the licensee's personnel revealed that while there is not an explicit prohibition to using XI4.ID2, "Commitment Change Process" with its change management flowchart for "single task" commitments, site practice and procedural intent is to utilize X14.ID2 for PCD entered "recurring task" commitments only.
Further NRC staff interviews with the licensee's personnel revealed that should there be a change required to a "single task" commitment, then the review process for modification of a corrective action program corrective action would evaluate the change. Following a review of modified "single task" commitments, the NRC staff identified that the NEI 99-04 flowchart guidance within
-5 of X14.ID2 and Form DCP 69-20200 were not being utilized to evaluate the notification or evaluation needed for this commitment change. below provides specific examples of this issue with recent "single task" commitments. No safety significant issues connected to this programmatic deficiency were noted. The licensee initiated Notification number 50435196 to address this issue.
Based on the review of the reports provided by the licensee as described above, queries of the PCD, the corrective action program, and the regulatory services stand-alone spreadsheet and the accompanying change review and tracking forms provided during the audit, the NRC staff found that the licensee's implementation of its program for managing NRC commitment changes is in accordance with its site procedure with the programmatic deficiencies noted above in the examples documented in Attachment 2.
3.0 CONCLUSION
Based on the audit, the NRC staff concludes that (1) the licensee has generally implemented NRC commitments on a timely basis, and (2) the licensee has implemented its program for managing NRC commitment changes with programmatic inconsistencies and deficiencies noted.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Steven Zawalick Corrado Sansone Mark Padovan Philippe Soenen Principal Contributor: James T. Polickoski Date: January 17, 2012 Attachments:
- 1. Audit Summary - Implementation of Commitments
- 2. Audit Summary - Management of Changes to Regulatory Commitments
ATTACHMENT 1 AUDIT
SUMMARY
. IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21! 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2
AUDIT
SUMMARY
- IMPLEMENTATION OF COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT. UNITS 1 AND 2 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Description of Commitment Supporting Documents Implementation Status Gl DCl-11-035 3/17/2011 Supplement to Response to Nuclear Regulatory Commission (NRC) Generic letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" No explicit
- number, tracked as a "one-time commitment" per XI4.ID1.
Pacific Gas and Electric Company (PG&E) will perform an ultrasonic test (UT) inspection at this local high point to inspect for gas accumulation following the dynamic venting of the residual heat removal (RHR) heat exchangers coming out of Unit 2 Refueling Outage Sixteen (2R16) and Unit 2 Refueling Outage Seventeen (2R17).
Notification 50037662 CLOSED - Commitment completed for 2R16 as described.
Gl DCl-08-090 10/14/2008 Nine-Month Response to NRC Generic letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" The 16 th commitment in the PG&E letter but has no programmatic number since tracked as a "one-time commitment" per X14.1D1.
PG&E will require that dynamic venting be performed for 10/1112009 each unit to flush out any gas from the RHR heat exchanger after each reactor coolant system (RCS) vacuum refill operation by 10/11/2009.
Notification 50037662 CLOSED - Commitment closed as a "recurring task" commitment to T36602 and is implemented in Operating Procedure (OP) 8-2:XI.
-2 Commitment Source Commitment Commitment Commitment Supporting Type Document Date Subject Number Description of Commitment Documents Implementation Status Bl Bl2007-01 DCL-08-011 21712008 Physical Security Plan Change No explicit number. It is a Security commitment with no current Implement a Physical Security Plan change to perform training In Security Department procedure SP 210.
NCR 60025143 NCR 60027840 CLOSED - Commitment implemented in the Physical Security Plan training procedure as a document reference. As Security commitments are not tracked in the tracking system. It would be classified as a Procedure Commitment Database (PCD), the training procedure is the only reference for its completion.
"recurring task" commitment per XI4.ID1.
CLOSED - Commitment closed and implemented via STP M-67B-1.
Other DCl-05-058 5/25/2005 B5b 1.16 Commitment that is security related and withheld from public disclosure in accordance with Title 10 of the Code STP M-67 ECG 18.2 of Federal Regulations Section 2.390 (10 CFR 2.390).
Other DCL-07-001 1/11/2007 B5b 1.30 Commitment that is security related and withheld from public disclosure in accordance with 10 CFR 2.390.
Notification 50382443 EP MT-21 CLOSED - Commitment closed and implemented via Notification 50382443, Tasks 2 and 3 to include verification of equipment in its location.
Other DCl-07-051 5/8/2007 B5b 2.60 Commitment that is security related and withheld from public disclosure in accordance with 10 CFR 2.390.
CP M-6 FTFT 001 FTFTD 009 CLOSED - Commitment closed and implemented via CP M-6 and Notification 50399546 Task 11 with training held over the last 4 years.
Notification 50399546 LAR DCl-09-009 4/24/2009 Revision to Technical Specification (TS) 3.3.1 No explicit
- number, tracked as a "one-time commitment" per XI4.ID1.
PG&E will use the NRC-approved methodology in Westinghouse WCAP-11394-P-A for each fuel cycle to ensure the minimum departure from nucleate boiling ratio (DNBR) is maintained above the DNBR safety limit.
Notification 50200784 CLOSED - Commitment closed and implemented in the design of both cores in previous cycles and in Notification 50200784, Task 7.
- 3 Type LAR LAR Commitment Source Document DCl-09-032 DCl09-065 Commitment Date 5/5/2009 9/8/2009 Commitment Commitment Subject Number 10 CFR Part No explicit 26 TS changes number, per TSTF-511 tracked as a "one-time commitment" per XI4.ID1.
Emergency No explicit Amendment
- number, Request to tracked as a revise TS 3.7.1 "one-time commitment" per XI4.ID1.
Description of Commitment PG&E will perform removal of the plant-specific TS requirements concurrently with the implementation of the 10 CFR Part 26, Subpart I requirements. This commitment will be completed no later than 10/112009.
PG&E will calculate the required as-found and as-left tolerances in accordance with the guidance of Regulatory Issue Summary (RIS) 2006-17 prior to the adjustment of the Diablo Canyon Power Plant (DCPP) Unit 2 Maximum Allowable Power Range Neutron Flux High Setpoint from 87 percent to 106 percent during DCPP Unit 2 Cycle 15.
Supporting Documents Notification 50043129 License Amendment 205 and 206 Notification 50265286 license Amendment 208 Calculation J 154 STP 1-37 N41.AlB Implementation Status CLOSED - Commitment closed and implemented via TS implementation on 10/1/2009 as noted in Notification 50043129.
CLOSED - Commitment closed and implemented in STP 1-37-N41A1B 44A1B, ECG 38.3, and Notification 50265286.
STP 1-37 N44.AlB ECG 38.3 Order 60019185-00101 002010030/0040 RIS 2006-17 LAR DCl-10-018 2/24/2010 Revision to TS 3.8.1 No explicit
- number, tracked as a "one-time commitment" per X14.1D1.
PG&E will provide additional guidance to operators in the surveillance procedures as part of implementation of the license amendment request to provide guidance to the operators on use of the new Note added to Surveillance Requirement (SR) 3.8.1.10 and SR 3.8.1.14.
TSTF-493 Rev 4 Notification 50232181 CLOSED Commitment deleted as DCl-10-018 was withdrawn voluntarily by the licensee as noted in Notification 50232181, Task 9.
AITACHMENT 2 AUDIT
SUMMARY
- MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2
AUDIT
SUMMARY
- MANAGEMENT OF CHANGES TO REGULATORY COMMITMENTS OCTOBER 18-21, 2011 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 Type GL Commitment Source Document DCL-10-014 DCL-11-035 Commitment Date 2/9/2010 3/17/2011 Commitment Subject Response to Nuclear Regulatory Commission (NRC) Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Commitment Number No explicit
- number, tracked as a "one-time commitment" per XI4.ID1.
Original Description of Commitment Pacific Gas and Electric Company (PG&E) will install a vent at this high point on the residual heat removal (RHR) pump line during Unit 2 refueling outage sixteen (2R16).
Revised Commitment PG&E will install a vent at this high point on the RHR line during Unit 2 Refueling Outage Eighteen (2R 18).
Supporting Documents DCL-11-035 Change Status DISCREPANCIES NOTED - X14.ID1 does not provide a mechanism for a "single task" or "one time" commitment to enter XI4.ID2.
Therefore, and DCPP Form 69-20200 of X14.ID2 was not utilized as required by the Nuclear Energy Institute (NEI) 99-04 guidance to evaluate the notification or evaluation needed for this commitment change. No safety significance noted.
- 2 Commitment Source Commitment Commitment Commitment Original Description of Supporting Type Document Date Subject Number Commitment Revised Commitment Documents Change Status Gl DCl-08-090 10/14/2008 Nine-Month The 4th PG&E will replace air The Unit 2 valves were Notification DISCREPANCIES Response to commitment operated valves in the replaced as delineated.
50037662 NOTED - XI4.1D1 NRC Generic in the PG&E safety-injection (SI) test For unit 1 during 1 R16, does not provide a letter 2008-01,
letter but has lines 2R15 with manual only the air-operated mechanism for a "Managing Gas no valves. An additional valves were replaced (10
'single task" or 'one-Accumulation in programmatic valve will also be added of the originally discussed time" commitment to Emergency number since 1R16 in series in each test 19 valves).
enter X14.1D2.
Core Cooling, tracked as a loop. These changes will Therefore, Decay Heat "one-time provide a more reliable and Removal, and commitment" isolation for test lines, Diablo Canyon Power Containment per X14.1D1.
decreasing the probability Plant (DCPP) Form Spray Systems" of intersystem leakage 69-20200 of X14.ID2 which could result in gas was not utilized as intrusion. These required by the NEI modifications will be 99-04 guidance to performed during 2R 15 evaluate the and 1R16.
notification or evaluation needed for this commitment change. The licensee provided an engineering evaluation in the Notification and did call the NRC project manager (PM).
No safety significance noted.
LAR DCl-89-320 12121/1989 "Diablo Canyon None Mode Transition Checklists The commitment remained DCl-89-320 Form 69-20200 Units 1 and 2 provided were revised due to the same with the submitted and Additional provisions in Technical exception of the TS approved with no Information and Specification (TS) 3.0.4 reference for TS 3.0.4.b discrepancies noted.
Certification with review by the Plant only regarding Staff Review Committee.
License Amendment Request 88-05, revision of Technical Specification (TS) Sections 3.0 and 4.0
'Applicability' and Associated Bases (generic letter 87-09)"
______ L______
- 3 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Status BL DCL-03-008 DCL-03-151 1/31/2003 11/18/2003 Leakage From Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity" None provided.
Bare metal inspection of reactor pressure vessel bottom heads.
Deleted due to updated ASME Code case N-722 ASME Section XI Code Case N-722 (73 FR 52730; 9/10/2008).
Form 69-20200 submitted and approved with no discrepancies noted.
LAR DCL-81-302 3/2/1981 Containment recirculation sump and RHR pump suction piping debris inspection T04781 The inspection of the containment recirculation sump and RHR pump suction piping to Valves 8982A an 8982B {shall be}
conducted by representatives of the engineering department and verified by personnel with knowledge equal to that of the performer. The containment recirculation sump, the sump trash racks, screens, and RHR pump suction lines {shall be} inspected for debris.
Any debris {shall be}
removed from containment and recorded on the inspection sheet. This inspection {shall be}
conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages.
The inspection of the containment recirculation sump and RHR pump suction piping to Valves 8982A an 8982B {shall be}
conducted by representatives of the engineering department and verified by personnel with knowledge equal to that of the performer.
Sump plenum internals and RHR pump suction lines to Valves 8982A and 8982B will only be inspected if a plenum hatch seal is broken or if an initiating event as defined in Surveillance Test Procedure STP M 45A has occurred. Any debris {shall be} removed from containment and recorded on the inspection sheet. This inspection
{shall be} conducted at least once per 24 months, normally in conjunction with the inspection following refueling outages.
Notification 0002152 DCP C-49S57 Form 69-20200 submitted and approved with no discrepancies noted.
- 4 Type Commitment Source Document Commitment Date Commitment Subject Commitment Number Original Description of Commitment Revised Commitment Supporting Documents Change Status LER LER 2-87 10/1212000 Accumulator T36157 As a result of Accumulator Revise the operations ONCR DC2 Form 69-20200 023-02 (Procedure Commitment Nozzle cracking Nozzle Cracking found in the early 1990s, monthly inspection procedures to examine all 91-TN-N075 submitted and approved with no DCl93-266 Database (PCD) update date)
Nonconformance Report (NCR) DC2-91-TN-N075 CAPR #3 stated, "Revise the weekly containment inspection rounds sheets to examine all accessible nozzles and underskirt piping for evidence of boric acid crystals which could indicate a through-wall crack.
accessible accumulator nozzles and underskirt piping for evidence of boric acid crystals that could indicate through wall cracks.
OP1.DC3 Notification
- 50375715, 50375714 STP 1-1F discrepancies noted.
Licensee noted and corrected in 2000 that the original commitment was not properly logged in PCD.
lER NRC Inspection Report 50 275192-17 and 50 323/92-17.
Non conformance report N001627 (NCR DCO 92-MM-N007)
DCl92-068 lER 1-91 019-00 DCl-92-134 lER 1-91 019-01 DCl-92-161 7/911992 PCD update 1111112003 07/30/1992 PCD update 11/1112003 Containment Fan Cooler Unit (CFCU)
Backdraft Dampers Backdraft Damper Maintenance T34927 T34928 The CFCU Surveillance Test Procedure (was) revised to specifically verify backdraft damper operability (DCl 92-(68).
STP M-93a, "CFCU Test,"
for backdraft dampers will be revised to adequately verify backdraft damper operability following CFCU maintenance (DCl92-161). The post-maintenance testing procedure (was) revised to include steps to backdraft damper critical safety function. Procedures (were) developed for backdraft damper maintenance with appropriate QC hold pOints (DCl 92-068).
Maintenance procedure (MP) M-23.8 is being developed to provide more specific instructions for CFCU backdraft damper maintenance (DCl92-161).
DELETE - No commitments remain for the Unit 2 backdraft dampers.
STP M-93A MP M-23.8 DCP 1000000119 DCP 1000000108 Form 69-20200 submitted and approved with no discrepancies noted.
J. Conway
- 2 If you have any questions, please contact me at 301-415-1445 or via e-mail at alan. wang@nrc.gov.
Docket Nos. 50-275 and 50-323
Enclosure:
Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:
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Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation OFFICE NRR/LPL4/PM NRR/LPL4/PM 4/LA NRR/LPL4/BC NRR/LPL4/PM NAME JPolickoski AWang JBurkhardt MMarkley AWang TE 12/22/11 1/9/12 1/5/12 1/17/12 1/17/12 OFFICIAL RECORD COpy