ML12128A050

2012 Regulatory Commitment Management Audit

ML12128A050
Person / Time
Site:	Hatch, 05000363
Issue date:	05/04/2012
From:	Boyle P G Division of Operating Reactor Licensing
To:	Tipps S B Southern Nuclear Operating Co
References
Download: ML12128A050 (5)

Text

1 NRR-PMDAPEm Resource From:Boyle, Patrick Sent: Friday, May 04, 2012 2:23 PM To: 'Stringfellow, N. Jack'; 'Tipps, Steve B.';

'Midlik, David W.'; 'Agee, Stephanie Y.'; 'Reddick, Rachelle G.'; 'Ajluni, Mark J.'

Cc: Martin, Robert; Salgado, Nancy; Hardage, David; Morris, Eddie

Subject:

Hatch 2012 Regulatory Commitment Management Audit

SUBJECT:

NOTIFICATION OF TRIENNIAL COMMITMENT MANAGEMENT AUDIT AT THE EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 (Hatch) Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Mr. Steve Tipps: The purpose of this email is to (1) notify you that I will conduct a triennial Commitment Management Audit for Hatch during the month of May 2012, including a site from May 15, 2012 to May 16, 2012, and to (2) request your assistance in this audit, particularly during the site visit. This is a follow up to the previous email on this subject. Through 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 (N EI) 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's 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 to determine if regulatory commitments are being effectively implemented. The NRC Office Instruction guiding this audit are LIC-105 "Managing Regulatory Commitments Made by Licensees to the NRC" (Agency-wide Documents Access and Management System (ADAMS) Accession Number ML090640415) and LIC-111 "Regulatory Audits" (ML082900195), both documents are publically available. In addition the Office of Inspector General (OIG) at the NRC completed an audit of this program and issued OIG-A-17 on September 19, 2011. The OIG provided several recommendations including a recommendation to review all open regulatory commitments to determine if any should be elevated to an obligation. The last on-site visit in support of the commitment management programs for Hatch was performed July 14-16, 2009. Portions of the audit were performed at the NRC Headquarters using documentation provided by Southern Nuclear Company (SNC - the licensee) as requested by the NRC staff. An audit report was issued October 29, 2009 (ML092990218) and describes the methodology I will use when conducting my audit. As noted, part of the audit will be a visit to the Hatch site. The purpose of the site visit is to obtain information and documentation needed to support the audit, to become more familiar with the Hatch (SNC) commitment management program, and to have the opportunity, if needed, to observe plant changes made in response to regulatory commitments. The types of documents that I will be interested in reviewing, and possibly obtaining, are listed in the section at the end of this email entitled "List of documents requested in support of the 2012 Triennial Commitment Management Audit for Hatch." I will also be utilizing a portion of my site visit to orient myself to the Hatch site as part of my regular project manager duties during my visit. The following is a discussion of other support issues associated with the audit:

2 Office Space I have identified office space within the Resident Inspector's office at Hatch for the week of May 14, 2012. If documents are located at a distance from these offices, then I may request a small working area in proximity to records of interest.

Schedule I will likely arrive in Baxley, GA area late on Monday May 14, 2012. My current plan is to spend Tuesday and Wednesday on site at Hatch.

Provision of Documents and Other Materials Please contact me prior to preparing copies of the materials in the "List of documents requested in support of the "2012 Triennial Commitment Management Audit for Hatch." I wish to minimize your administrative burden by specifically identifying those documents required for my audit report preparation. I may request that specific documents be made available to me in my temporary office space. If there are handling requirements (e.g. proprietary, security, etc), please communicate with me beforehand. During my site visit I may also request to speak with the Site Commitment Coordinator for the plant and corporate. I may also request to speak with knowledgeable plant engineering and licensing organization personnel regarding implementation of the commitments being reviewed.

Reactor Access I would like to have reactor site access including access to the control room if possible. I may not require this as part of my audit but it would be very helpful as part of my Project Manager site orientation. I have completed the annual site access training for the NRC.

References The following references may be of assistance in your preparations to support this audit: 1. SECY-95-300, Nuclear Energy Institute' s Guidance Document, "Guideline for Managing NRC Commitments, dated December 20, 1995 (ADAMS Accession No. ML060270189). 2. SECY 98-224, "Staff and Industry Activities Pertaining to the Management of Commitments Made by Power Reactor Licensees to the NRC," dated September 28, 1998 (ADAMS Accession No.

ML992870043). 3. SECY 00-045, Acceptance of NEI 99-04, "Guidelines for Managing NRC Commitment Changes," dated February 22, 2000 (ADAMS Accession No. ML003679799). 4. NEI 99-04, "Guidelines for Managing NRC Commitment Changes," July 1999 (ADAMS Accession No.

ML003680088). 5. Letter from S. Collins (NRC) to R. Beedle (NEI) dated March 31, 2000 (ADAMS Accession No.

ML003696998). 6. Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (ADAMS Accession No. ML003741774). 7. NRR Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession Number ML082900195). 8. NRR Office Letter 900, "Managing Commitments Made by Licensees to the NRC," (ADAMS Accession Number ML003692416). 9. NRR Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensee to the NRC" (ADAMS Accession Number ML090640415 310. OIG Audit Report OIG-A-17 "Audit of NRC's Management of Licensee Commitments" dated September 19, 2011.

Available on the NRC public web site NRC Library, Document Collections, Inspector General Reports, 2011.

"List of documents requested in support of the 2012 Triennial Commitment Management Audit for Hatch."

I have already received and reviewed NMP-GM-019, "Commitments Management." I would like to see any addition site implementation procedures that support the corporate document and would like to observe the use of the tracking database. I would like to review plant documentation (Condition Reports, procedures, work orders, etc.) associated with implementation of commitments listed below for Hatch: 1) NL-07-0894 "Provide alternative safety related power supply to HNP Units 1 and 2 turbine building ventilation exhaust systems with a manual switchover" - COMPLETE (original due date 04/30/10). 2) NL-08-0345 "Perform Section XI, Appendix VII, Supplement 10 examinations of dissimilar metals welds, no later than the completion of refueling outage 1R24 in Spring of 2010" COMPLETE 3) NL-08-0512 "Perform inspections for items a - f and re-examine support plate gussets associated with the anchorages for the shroud tie rods using an enhanced visual inspection (EVT - 1) at 1RF023, 1RF024, 1RF028, and 1RF032. 1RF023 and 1RF024 COMPLETE, 1RF028 and 1RF032 OPEN 4) NL-08-1340 "Revise procedures to provide assurance that gas in affected systems suction piping is limited to the acceptance criteria determined by the HNP specific analyses. Additionally, HPCI system post maintenance fill and vent procedures used to provide assurance that gas in the HPCI system suction piping is limited to within the acceptance criteria (including the impact of gas trapped in valve bonnets) will be revised based on the HNP specific analyses." COMPLETE (original due date 3/17/10 Unit 1 and 3/18/09 Unit 2) 5) NL-09-0172 "SNC will implement the requirements of 10 CFR Part 26, Subpart I, concurrent with the elimination of TS 5.2.2(e). STATUS NOT SPECIFIED. The amendment approved on 09/04/09 (ML091770664) and per the license amendment the revision to the license is to be implemented by October 1, 2009. 6) NL-09-0344 (NL-09-0442) "Implement design changes to eliminate operator manual actions not in compliance with 10 CFR Part 5, Appendix R, III.G.2. COMPLETE, multiple items and dates (with

revisions). 7) NL-09-1803 "Submit a Unit 2 Technical Specification based on the TSTF or submit a plant specific TS change within a year after the issuance concerning gas intrusion" OPEN with conditional due date (describe actions to date, status, and method of monitoring) 8) NL-10-0858 "Submit a Unit 1 Technical Specification based on the TSTF or submit a plant specific TS change within a year after the issuance concerning gas intrusion" OPEN with conditional due date (describe actions to date, status, and method of monitoring) 9) NL-10-1001 "Complete a root cause determination that address the broadness review and extent of condition for issues associated with preventative maintenance schedules of safety-related components that have a service life. If further actions develop as a result that impact compliance, then this response letter will be updated to include additional actions." - COMPLETE (original due date 8/16/10) 10) NL-11-0167 "Perform code repair of identified flaw in Unit 1 PSW system at intake structure" COMPLETE (original due date 03/18/12).

4 Conclusions of the previous audit will be evaluated against current practices to determine if the areas for improvement have been or are being addressed. Your cooperation and support during this audit and site visit will be appreciated. If you have questions concerning this audit, feel free to contact me.

Thank you, Patrick G. Boyle NRC DORL Project Manager - Hatch and Vogtle

301-415-3936

Hearing Identifier: NRR_PMDA Email Number: 358 Mail Envelope Properties (C070F82E831E1C44879BFA258CF960C990D354F314)

Subject:

Hatch 2012 Regulatory Commitment Management Audit Sent Date: 5/4/2012 2:23:02 PM Received Date: 5/4/2012 2:23:00 PM From: Boyle, Patrick Created By: Patrick.Boyle@nrc.gov Recipients: "Martin, Robert" <Robert.Martin@nrc.gov>

Tracking Status: None "Salgado, Nancy" <Nancy.Salgado@nrc.gov>

Tracking Status: None "Hardage, David" <David.Hardage@nrc.gov> Tracking Status: None "Morris, Eddie" <Eddie.Morris@nrc.gov> Tracking Status: None "'Stringfellow, N. Jack'" <NJSTRING@southernco.com> Tracking Status: None "'Tipps, Steve B.'" <sbtipps@southernco.com> Tracking Status: None

"'Midlik, David W.'" <DWMIDLIK@southernco.com> Tracking Status: None "'Agee, Stephanie Y.'" <SYAGEE@southernco.com>

Tracking Status: None "'Reddick, Rachelle G.'" <rgreddic@southernco.com> Tracking Status: None "'Ajluni, Mark J.'" <MJAJLUNI@southernco.com> Tracking Status: None

Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 10328 5/4/2012 2:23:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: