ML082060564
| ML082060564 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/29/2008 |
| From: | Vaaler M NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Walt T Carolina Power & Light Co |
| Vaaler, Marlayna, NRO/DNRL 415-3178 | |
| References | |
| TAC MD8760 | |
| Download: ML082060564 (15) | |
Text
July 29, 2008 Mr. Thomas D. Walt, Vice President H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550-0790
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD8760)
Dear Mr. Walt:
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines 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 programs are consistent with the industry guidance in NEI 99-04, and to ensure that the regulatory commitments are being effectively implemented.
An audit of the H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP), commitment management program was performed at the plant site in Hartsville, South Carolina, between June 11, 2008, and June 12, 2008. The NRC staff concludes, based on the audit, that HBRSEP (1) has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report. Please contact me at (301) 415-3178 if you have questions.
Sincerely,
/RA/
Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
Audit Report cc w/enclosure: See next page
July 29, 2008 Mr. Thomas D. Walt, Vice President H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550-0790
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD8760)
Dear Mr. Walt:
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines 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 programs are consistent with the industry guidance in NEI 99-04, and to ensure that the regulatory commitments are being effectively implemented.
An audit of the H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP), commitment management program was performed at the plant site in Hartsville, South Carolina, between June 11, 2008, and June 12, 2008. The NRC staff concludes, based on the audit, that HBRSEP (1) has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report. Please contact me at (301) 415-3178 if you have questions.
Sincerely,
/RA/
Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
Audit Report cc w/enclosure: See next page DISTRIBUTION:
PUBLIC LPL2-2 R/F RidsNrrPMMVaaler RidsNrrLACSola RidsNrrDorlLpl2-2 RidsOgcRp RidsAcrsAcnw&mMailCenter RidsRgn2MailCenter RidsNrrPMBMoroney LRegner, NRR ADAMS Accession Number: ML082060564 NRR-106 OFFICE LPL2-2/PM LPL2-2/LA LPL2-2/BC NAME MVaaler CSola TBoyce DATE 07/29/08 07/29/08 07/29/08 OFFICIAL RECORD COPY
Mr. T. D. Walt H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 cc:
Mr. Ernest J. Kapopoulos, Jr. Mr. J. Paul Fulford Plant General Manager Manager, Performance Evaluation and H. B. Robinson Steam Electric Plant, Regulatory Affairs PEB 5 Unit No. 2 Progress Energy Carolinas, Inc.
Progress Energy Carolinas, Inc. Post Office Box 1551 3581 West Entrance Road Raleigh, North Carolina 27602-1551 Hartsville, South Carolina 29550 Mr. David T. Conley Mr. Eric McCartney Associate General Counsel II - Legal Director of Site Operations Department H. B. Robinson Steam Electric Plant, Progress Energy Service Company, LLC Unit No. 2 Post Office Box 1551 Progress Energy Carolinas, Inc. Raleigh, North Carolina 27602-1551 3581 West Entrance Road Hartsville, South Carolina 29550 Public Service Commission State of South Carolina Mr. Curt Castell Post Office Drawer 11649 Supervisor, Licensing/Regulatory Programs Columbia, South Carolina 29211 H. B. Robinson Steam Electric Plant, Unit No. 2 Ms. Beverly Hall, Section Chief Progress Energy Carolinas, Inc. N.C. Department of Environment 3581 West Entrance Road and Natural Resources Hartsville, South Carolina 29550 Division of Radiation Protection 3825 Barrett Dr.
Mr. C. T. Baucom Raleigh, North Carolina 27609-7721 Manager - Support Services - Nuclear H. B. Robinson Steam Electric Plant, Mr. Robert P. Gruber Unit No. 2 Executive Director Progress Energy Carolinas, Inc. Public Staff - NCUC 3581 West Entrance Road 4326 Mail Service Center Hartsville, South Carolina 29550 Raleigh, North Carolina 27699-4326 Mr. Scott D. West Ms. Susan Jenkins Superintendent - Security South Carolina Department of Health H. B. Robinson Steam Electric Plant, Bureau of Land & Waste Management Unit No. 2 2600 Bull Street Progress Energy Carolinas, Inc. Columbia, South Carolina 29201 3581 West Entrance Road Hartsville, South Carolina 29550 Ms. Margaret A. Force Assistant Attorney General U. S. Nuclear Regulatory Commission State of North Carolina Resident Inspectors Office Post Office Box 629 H. B. Robinson Steam Electric Plant Raleigh, North Carolina 27602 2112 Old Camden Road Hartsville, South Carolina 29550 Mr. John H. ONeill, Jr.
Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW.
Washington, DC 20037-1128
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261
1.0 INTRODUCTION AND BACKGROUND
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines 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 programs are consistent with the industry guidance in NEI 99-04, and to ensure that the regulatory commitments are being effectively implemented.
NEI 99-04 defines a Aregulatory 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 H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP), commitment management program was performed at the plant site in Hartsville, South Carolina, between June 11, 2008, and June 12, 2008. As this was the first audit recorded, the audit reviewed commitments made since 2000. 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.
Enclosure
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, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation may be included in the sample, but the review will be limited to verification of restoration of compliance, not the specific methods used. Before the audit, the NRC staff searched the Agencywide Documents Access and Management System for the licensee=s submittals during in the last several years and selected a representative sample for verification.
The selection of the sample list covered a variety of systems, disciplines and licensing actions important to the NRC staffs decision-making process. This list also included commitment changes.
The licensee was asked to provide a list of regulatory commitments related to licensing actions from its commitment management system. The NRC staff again ensured that the selected sample related to the licensees licensing action and licensing activity submittals and asked the licensee to provide documentation to support the audit. The licensee provided the list and the documentation to support the NRC staffs audit in each of the sample areas discussed above.
The licensees documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (i.e., plant procedures, engineering changes, or other plant documents). The Audit Summary table lists the commitments selected for this audit.
The audit excluded the following types of commitments that are internal to licensee processes:
(1) Commitments made on the licensee=s own initiative among internal organizational components.
(2) Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.
(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications (TSs), and Updated Final Safety Analysis Reports (UFSARs). 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 NRC staff reviewed documentation generated by the licensee related to the sample items listed in the attached table that are categorized as commitments in response to different categories of documents, in order to assess the implementation of the regulatory commitment, including the completion status. For the sample of commitments selected for the audit, the NRC staff found that the licensee had adequately captured all of the regulatory commitments in their PassPort© system, which is a data management and tracking tool. The review of the sample commitments in the PassPort© database reflected their status consistent with the commitment program. The attached Audit Summary table provides details of the audit and its results.
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 HBRSEP is contained in REG-NGGC-0110, Regulatory Commitments.
The audit reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The audit also verified that HBRSEP=s commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee staff 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 REG-NGGC-0110 includes the following statements, which provide guidance to the licensee that is consistent with the intent of NEI 99-04, and ensure that HBRSEP is appropriately implementing regulatory commitments, as well as tracking changes to the commitments:
In the case where a third party (e.g., NEI, an owners group, or another organization) has been authorized to make Regulatory Commitments on behalf of the Licensee, the affected Licensee shall ensure that statements represented as Regulatory Commitments are appropriately documented and are subsequently managed in accordance with REG-NGGC-0110.
Docketed correspondence containing action items shall also contain an explicit statement concerning the existence of any Regulatory Commitment.
Once made, Regulatory Commitments shall be considered non-discretionary and shall be changed only as described in REG-NGGC-0110.
Each Regulatory Commitment shall be captured in a PassPort© Action Request (AR).
Appropriate actions to implement Regulatory Commitments shall be captured in a PassPort© Action Tracking Assignment.
Once accepted, any action inherent to the successful implementation of a Regulatory Commitment shall be considered non-discretionary and shall only be changed as described in REG-NGGC-0110.
The Responsible Licensing Supervisor, or designee, shall ensure the accuracy of any implicit or explicit re-statement of a Regulatory Commitment in docketed correspondence received from the NRC to ensure that written or oral communication has not been misconstrued.
Except for discretionary enforcement situations, advise the NRC that an oral statement to take a certain action represents an intent to make a Regulatory Commitment but does not constitute a Regulatory Commitment until submitted by the Licensee in writing on the docket.
An Assignment associated with a Regulatory Commitment must include appropriate reference to implementing documentation to provide traceability for the Regulatory Commitment.
The Responsible Licensing Supervisor, or designee, shall consider the need to incorporate the Regulatory Commitment into an NRC mandated licensing basis document such as the UFSAR, Quality Assurance Program, Emergency Plan, Security Plan, Fire Protection Program, etc.
If it becomes apparent that an Assignment cannot be implemented as described by the due date, the responsible individual/group shall promptly contact the Responsible Licensing Supervisor, or designee, with a proposed revision.
If a Regulatory Commitment is not implemented as described by the due date or if non-compliance with Regulatory Commitment occurs, the Responsible Licensing Supervisor, or designee, shall initiate a Nuclear Condition Report, and, if necessary, notify the NRC.
When notified of the need to change a Regulatory Commitment, the Responsible Licensing Supervisor, or designee, shall ensure an Assignment is initiated to the individual/group that includes a Regulatory Commitment Change Evaluation, The Responsible Licensing Supervisor, or designee, shall review the Regulatory Commitment Change Evaluation, including any necessary supporting documents, and verify the actions that need to be taken based on the results.
As appropriate, the Responsible Licensing Supervisor, or designee, shall record the basis for authorizing or not authorizing the change, as well as submit docketed correspondence and capture the revised Regulatory Commitment.
The Responsible Licensing Supervisor, or designee, may also authorize revision of the scope or committed date for a Regulatory Commitment based on related correspondence submitted to the NRC.
It may be appropriate to track the reporting of the Regulatory Commitment change(s) consistent with the frequency of the next UFSAR update or biennially.
The Responsible Licensing Supervisor, or designee, shall ensure that any revised Regulatory Commitment, that satisfies the criteria for reportability to the NRC in the Regulatory Commitment Change Evaluation, is included on a summary report of Regulatory Commitment changes which is submitted on a frequency consistent with 10 CFR 50.71(e) UFSAR updates or biennially.
When making changes to procedures or other documents used to implement a Regulatory Commitment, the responsible organization ensures that the changes do not invalidate compliance with the applicable Regulatory Commitment.
When canceling procedures or other documents used to implement a Regulatory Commitment, the responsible organization ensures that the Regulatory Commitment is still being met and is properly referenced in another appropriate document to ensure continued implementation of the Regulatory Commitment.
If the Regulatory Commitment is no longer needed and a change is warranted, the responsible organization may request a change per the guidance in REG-NGGC-0110 In addition, the NRC staff reviewed documentation from the licensee related to the sample items listed in the attached table that involved changes to commitments. The NRC staff found that the licensee properly addressed each regulatory commitment change selected for this audit and has implemented an effective program to manage commitment changes.
The NRC staff found that REG-NGGC-0110 adequately conforms to the guidance and intent of NEI 99-04 for commitment tracking, the commitment change process, traceability of commitments, and reporting requirements. Discussions with HBRSEP staff confirmed that REG-NGGC-0110 is being implemented in its entirely at the plant, which further supports the NRC staffs conclusion that regulatory commitments are being handled in accordance with the guidance contained in NEI 99-04.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that HBRSEP (1) has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Curt Castell Supervisor - Licensing and Regulatory Programs Ray Crandall Licensing Engineer Principal Contributor: Marlayna Vaaler
Attachment:
Summary of Audit Results
AUDIT OF CAROLINA POWER AND LIGHT COMPANY MANAGEMENT OF REGULATORY COMMITMENTS AT H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 PERFORMED JUNE 11 AND 12, 2008 LIST OF COMMITMENTS INCLUDED IN THE AUDIT Action Due Date &
No. Category Letter No. Commitment Completion Method Request No. Completion Date Plant procedures will be revised by Regulatory PLP-006 Revision 51 was made August 1, 2001, to require Correspondence 8/1/2001 via DCF 2001P0859 to incorporate inspection of insulation on, and RNP-RA/ the inspection requirement; the 1 on the PAM 00031856 immediately below, the pressurizer requirement was added to both the 01-0094 head to ensure that no gaps, tears, Instrumentation 7/12/2001 general closeout and prior to Report or other visible signs of heatup closeout checklists degradation exist Regulatory A routine maintenance activity will PMR 2001-078 was processed and Correspondence 8/01/2001 be added to perform thermography PMID-RQ 26976-01 created to RNP-RA/ to the extent practical of the perform thermography of the 2 on the PAM 00031856 01-0094 pressurizer at an appropriate pressurizer insulation during Instrumentation 7/23/2001 temperature during outages to refueling outages, in Mode 4, prior Report inspect insulation performance to increasing power Testing for the Unit 2 control room License was performed the week of 1/31/2003 January 20, 2003; special Amendment for RNP-RA/ Perform a leak rate test on the Unit 3 00060673 procedure SP-1506 was used to the Alternate 02-0067 2 control room establish the system line up and 1/29/2003 Source Term provide guidance in performing the vendor (NCS/LAT) procedures Attachment
Action Due Date &
No. Category Letter No. Commitment Completion Method Request No. Completion Date A reanalysis of the AST events to support the control room air inleakage testing results was License determined not necessary as 3/7/2003 Revise analyses as necessary to Amendment for RNP-RA/ testing of the air inleakage resulted 4 00060673 incorporate the new control room the Alternate 02-0067 inleakage rate in measured values that were lower 3/3/2003 than those values used in the Source Term original AST events analysis; therefore the original AST events analysis remained bounding License A submittal to the NRC providing 2/28/2003 Prepare a licensing submittal to the preliminary inleakage test Amendment for RNP-RA/
5 00060673 provide the test results and update results was prepared and reviewed the Alternate 02-0067 the affected analysis, if necessary in advance of the final test results 2/24/2003 Source Term being submitted by the vendor The draft final report from the test vendor for the control room If control room leakage test shows License inleakage testing indicated that the 3/7/2003 the current licensing basis is not plant was not operating in its CLB Amendment for RNP-RA/ met, develop a comprehensive 6 00060673 for the 60 min to 30 day portion of the Alternate 02-0067 corrective action plan to restore the accident; AR 86280 was 3/4/2003 compliance with the GDC-19 dose Source Term initiated and an OD entered; the acceptance criteria OD was addressed and then exited by operations once evaluated License Letter RNP-RA/03-0013 was 4/22/2003 Amendment for RNP-RA/ Submit inleakage test results to the submitted to the NRC on 4/10/2003 7 00060673 the Alternate 02-0067 NRC providing the control room tracer 4/21/2003 gas inleakage test results Source Term Revise maintenance and All maintenance and calibration calibration procedures to procedures identified in the License 11/6/2002 incorporate Caldon maintenance affected document list for RNP-RA/
8 Amendment for 00061023 and calibration requirements prior EC 47152, EC 47162, and EC 02-0066 to declaring the LEFM system 47163 were revised to support the Power Uprate 11/6/2002 operable and raising power above power uprate and the LEFM the current licensed power level system
Action Due Date &
No. Category Letter No. Commitment Completion Method Request No. Completion Date License 11/29/2002 LEFM operability requirements Incorporate operability RNP-RA/ were established in TRM Section 9 Amendment for 00061023 requirements for the LEFM into the 02-0066 Technical Requirements Manual 3.25, issued in TRM Revision 15, Power Uprate 12/2/2002 on November 14, 2002 The drain inlet to the 1A and 1B feedwater heaters enters the shell beyond the tube bundle so that For those feedwater heater there is no effect on the tubes components that were evaluated to regardless of the condition of any exceed HEI guidelines, but that impingement plates; in reviewing License 11/6/2002 have not been recently measured the drawings for the 2A and 2B RNP-RA/
10 Amendment for 00061023 and inspected, measurement and heaters, it was determined that 02-0066 inspection of these feedwater there are no drain inlet Power Uprate 11/1/2002 heater components will be impingement plates installed; the performed prior to operating at the impingement plates in the 3A and uprated power condition 3B feedwater heaters were inspected during a refueling outage and there was no significant wear on the drain inlet piping and nozzle Replace the shell-side feedwater The secondary side plant project License 11/6/2002 heater relief valves with relief team reported that all shell-side RNP-RA/
11 Amendment for 00061023 valves that meet HEI guidelines feedwater relief valves were 02-0066 prior to operating at the uprated replaced with valves of adequate Power Uprate 10/28/2002 power condition capacity to meet the HEI guides Revise normal and abnormal All procedures for normal, off License 11/6/2002 operating procedures, emergency normal, and emergency operating RNP-RA/
12 Amendment for 00061023 operating procedures, and off- identified by the EC 47152, 02-0066 normal procedures prior to use at EC 47162, and EC 47163 affected Power Uprate 11/6/2002 the uprated power conditions documents lists were revised Revise operating procedures to indicate that temporary operation OP-105, OST-010, and the ERFIS License 11/6/2002 above the licensed power level alarm setpoints were revised to RNP-RA/ shall be limited to 0.3 percent of 13 Amendment for 00061023 support administrative controls that 02-0066 rated thermal power, consistent ensure plant operation less than Power Uprate 11/6/2002 with the reduced power 0.3 percent rated thermal power measurement uncertainty, prior to operation at uprated power levels
Action Due Date &
No. Category Letter No. Commitment Completion Method Request No. Completion Date Operator training was conducted in both the classroom and simulator starting September 30 and finishing October 8, 2002, as part of LOCT Cycle 02-05. This included all Provide simulator training on power License 10/11/2002 licensed operators and non-uprate related changes to the plant RNP-RA/ licensed shift technical advisors; 14 Amendment for 00061023 that affect operator performance 02-0066 prior to operating at uprated power this training included procedure Power Uprate 10/8/2002 changes impacted by the power levels uprate, AST project, and plant modifications; it also included TS, AST, and TRM changes in support of the power uprate; simulator training included similar aspects Complete hardware and software Hardware and software changes License 11/6/2002 changes, including changes were implemented using the RNP-RA/ involving plant process computer 15 Amendment for 00061023 following ECs: EC 47163, 02-0066 inputs, which affect operator EC 47152, EC 47139, EC 47162, Power Uprate 11/4/2002 performance prior to operation at EC 47804, and EC 48706 the uprated power level EC-TCHG 54382 was implemented A temporary modification will be on 9/23/2003; this temporary 9/30/2003 implemented, which will restore the modification restored the design Licensee Event RNP-RA/
16 00100967 design basis requirement that the basis for V12-10, 11, 12, and 13 in Report 2003-02 03-0098 switch failure will not prevent the that a switch failure will not prevent 9/29/2003 safety function the valves from performing their safety function 10/25/2003 Replace the control switch for the The control switch for vacuum relief Licensee Event RNP-RA/ vacuum relief valves (V12-12 and valves V12-12-34 and 14 was 17 00100967 Report 2003-02 03-0098 V12-13) and evaluate the removed removed on 9/24/2003 and sent to 10/6/2003 switch for any signs of degradation the EE Center for evaluation
Action Due Date &
No. Category Letter No. Commitment Completion Method Request No. Completion Date Review the safety related component control wiring diagrams to verify that redundant 10/25/2003 components are designed with Completed under AR 95470 AI 15, Licensee Event RNP-RA/
18 00100967 individual control switches in each which involved an evaluation by the Report 2003-02 03-0098 circuit, and that failure of individual Progress Energy EE Center 9/24/2003 component control switches alone will not cause a failure to fulfill a safety function Verify operability of the isolation 10/25/2003 function when a source is applied OST-924-3 to address the Licensee Event RNP-RA/ to radiation monitors R-11 and 19 00100967 functional check was approved on Report 2003-02 03-0098 R-12 by confirming functional 10/23/2003 10/24/2003 testing or establishing procedural guidance A permanent modification of the EC 54398, Control Wiring Change containment vacuum and pressure for Containment Pressure Relief 5/27/2004 relief control circuits will be Valves V12-10/11 and V12-12/12, Licensee Event RNP-RA/ installed to restore the design such 20 00100967 was completed on 5/20/2004 and Report 2003-02 03-0098 that the control switch is wired in turned over to operations; this 5/24/2004 series with the Train A and engineering change permanently Train B containment isolation restores the design basis relay contacts Regulatory Evaluate or examine the CV liner in 12/1/2014 These examinations of the CV liner Correspondence RNP-RA/ the area immediately above Panel 21 00135877 were completed by the committed on the RFO-22 04-0110 228-ZZZb at the Fuel Transfer date 3/7/2007 Canal ISI Report Regulatory Evaluate or examine the CV liner in 10/31/2010 These examinations of the CV liner Correspondence RNP-RA/ the area immediately above Panel 22 00135877 were completed by the committed on the RFO-22 04-0110 228-C1 at the Regenerative Heat date 3/7/2007 Exchanger Wall ISI Report 4/30/2007 The EHC system up/down counter Licensee Event RNP-RA/ Replace the turbine EHC card card was replaced with a new style 23 00217202 Report 2006-01 06-0120 during the 2007 refueling outage card (1B51049-101) under 4/27/2007 WO 990014
Action Due Date &
No. Category Letter No. Commitment Completion Method Request No. Completion Date Revise Construction Department 9/14/2007 Procedures CON-TRMC-00540 The transmission documents Licensee Event RNP-RA/
24 00239362 and CON-TRMC-00504 to include CON-TRMC-00540 and Report 2007-01 07-0067 tightness check of crimped CON-TRMC-00504 were revised 9/8/2007 connections including a pull test 11/2/2008 WO 1106292 has been created to Licensee Event RNP-RA/ Replace the B MDAFW pump 25 00239362 replace the B MDAFW pump Report 2007-01 07-0067 control switch during RFO-25 control switch 4/25/2008