ML11272A063
| ML11272A063 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/28/2012 |
| From: | Farideh Saba Plant Licensing Branch II |
| To: | Annacone M Carolina Power & Light Co |
| Saba, Farideh | |
| References | |
| TAC ME5438, TAC ME5439 | |
| Download: ML11272A063 (18) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 February 28,2012 Mr. Michael J. Annacone, Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME5438 AND ME5439)
Dear Mr. Annacone:
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the U. S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute 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 Carolina Power and Light Company's commitment management program was performed at the plant site during the period of September 13 and 14, 2011. Based on the audit, the NRC staff concluded that (1) Brunswick Steam Electric Plant (BSEP), Units 1 and 2 has implemented NRC commitments on a timely basis, and (2) BSEP has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, P-A--r':l},
Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324]
Enclosure:
Audit Report cc w/encl: Distribution via ListServ
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS BRUNSWICK STEAM ELECTRIC PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324
1.0 INTRODUCTION AND BACKGROUND
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute document (NEI) 99-.04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the licensee's regulatory commitments are being effectively implemented.
The document NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
2.0 AUDIT PROCEDURE AND RESULTS An audit of the Brunswick Steam Electric Plant (BSEP), Units 1 and 2 commitment management program was performed at the plant site during the period September 13 and 14,2011. The previous audit was done in June 2008 and recorded in the audit report dated September 30, 2008. This audit reviewed commitments made since the prior audit. 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.
Enclosure
2 2.1.1 Regulatory Commitments 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, or licensing activities. Before the audit, the NRC staff searched ADAMS for the regulatory commitments in the licensee's submittals since last audit for verification. In addition, the NRC staff reviewed the status of the regulatory commitments that were in progress during the last 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, 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 Regulatory Commitments Implementation Audit Results The licensee's commitment management program is described in the Progress Energy Corporation (PEC), Nuclear Generation Group, Standard Procedure REG-NGGC-011 0, Revision 3, "Regulatory Commitments." The PEC procedure is applicable to regulatory commitments made or modified after the effective date of this procedure.
The NRC staff reviewed the licensee's procedure REG-NGGC-011 0, Revision 3 and compared it to its previous revision that was reviewed by the NRC staff during the last audit. The NRC staff review identified that the following statement was added in Revision 3 of this procedure, regarding changes to commitment implementation date.
If a Regulatory Commitment has yet to be implemented and implementation plans change, the revised commitment can be implemented but the NRC should be notified of the change as soon as practicable after approval by appropriate management but before any comrnitted completion date. Notification should be accomplished by supplementing, or revising the docketed correspondence containing the original commitment.
The NRC staff found that REG-NGGC-0110, Revision 3 provides guidance to the licensee that is consistent with the intent of NEI 99-04, and that the licensee is
- 3 appropriately following its procedure for implementation of the regulatory commitments at the BSEP, Units 1 and 2.
The licensee's commitment database, which is called PassPort©, handles the commitments that are open or active. This database is used to track all commitments, including commitments to state and other agencies, and also tracks other plant activities. Each regulatory commitment is captured in a PassPort© Action Request (AR), a Nuclear Task Management is initiated, and appropriate actions to implement regulatory commitments are also captured in a PassPort© Action Tracking Assignment. The assignment type is usually entered as "COMM," which indicates that this action is an NRC regulatory commitment. Also entered are the due date and the responsible individual for meeting the commitment.
During the audit, the NRC staff reviewed the status of the implementation of the regulatory commitments that were made since the last audit and the commitments that were in progress at that time. The attached Summary of Audit Results table provides details of the audit and its results.
The NRC staff interviewed the BSEP personnel and reviewed documentation generated by the licensee related to the items listed in the attached table that are identified as regulatory commitments in response to different types of actions or communications (Category) with the NRC, in order to assess the implementation of each regulatory commitment, including the completion status. For the commitments reviewed during the audit, the NRC staff found that the licensee had adequately captured all of the regulatory commitments in its PassPort© database, which is a data management and tracking tool. The review of the identified commitments in the PassPort© database reflected their status consistent with the commitment program.
During the audit, the NRC staff reviewed plant procedures that have been revised as a result of commitments made by the licensee to the NRC. The NRC staff noted that the regulatory commitments are referenced in the affected procedures. In addition, the paragraphs of the procedures are marked by the referenced number assigned for those commitments. As such, the licensee's procedure owner will be advised to refer to all the regulatory commitments associated with each procedure, prior to making any changes to the procedure.
During the audit the NRC staff noticed that the AR for the regulatory commitment listed in the licensee's letter dated May 9, 2008, was closed (shown completed) later than the commitment scheduled completions date. However, the NRC staff verified that all activities associated with this AR were implemented during the refueling outage prior to the scheduled completion date.
Based on the above review, the NRC staff concluded that the licensee adequately implemented all the regulatory commitments made to the NRC in a timely manner.
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 compares 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 audit reviews a sample of commitment changes
-4 that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The audit also verifies that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.
2.2.1 Regulatory Commitment Changes Audit Results The process used at BSEP is contained in the PEC Standard Procedure REG-NGGC-0110, Revision 3. The NRC staff reviewed this procedure against NEI 99-04, Revision O. The REG-NGGC-0110, Revision 3 provides guidance to the licensee to ensure that BSEP is appropriately implementing regulatory commitment changes, as well as tracking changes to the commitments.
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. Regulatory commitment changes are processed and tracked by the responsible licensing supervisor, or designee. The evaluation of any commitment changes is to be done by using the "Regulatory Commitment Change Evaluation" form in Attachment 3 of the procedure. The NRC staff reviewed this form and found it to be consistent with the Commitment Evaluation form in NEI 99-04, with minor differences.
During the audit, the NRC staff reviewed Enclosure 2 of the licensee's letter dated August 20, 2008, that provided a summary of the BSEP regulatory commitment changes from August 1, 2006 to July 31,2008. The one regulatory commitment change reported in this letter was a change in the security related information that was originated by a letter from James Scarola (the licensee) to the NRC dated February 9,2007. The NRC staff noticed that this is not a regulatory commitment; rather it is the licensee's response to an NRC's security order.
However, the NRC staff noticed that this is consistent with the NEI proposal, as captured in the a safety evaluation attached to the NRC's letter dated August 23, 2007, that suggested that "the implementing details found to be acceptable means of meeting the license condition would be treated as commitments and managed in accordance with NEI 99-04." During the audit, the NRC staff found this approach acceptable, since it is endorsed by the NRC in its August 23, 2007, safety evaluation. The NRC staff also concluded that the licensee appropriately reported this change to the NRC.
During the audit, the NRC staff also reviewed Enclosure 2 of the licensee's letter dated August 18, 2010, that provided a summary of the BSEP regulatory commitment changes from August 1,2008 to July 31,2010. One regulatory commitment change reported in this letter regarding a commitment that was originated in a letter from the licensee, "Regulatory Operations Bulleting No. 73-6," dated December 13,1974. The original commitment stated, in part, that engineering safety feature (ESF) operability describes a procedure to be used by shift personnel for utilizing the ESF status board. The revised commitment states that the ESF status boards are no longer used and have been removed from the control room. During the audit, the NRC staff asked how this regulatory commitment change was screened. The licensee responded that in accordance with the PEC procedure, the screening papers are not retained after reporting to the NRC. During the audit, the NRC staff screened and evaluated
- 5 this commitment change using Attachment 3 of PEC Standard Procedure REG-NGGC-011 0, Revision 3. Based on this independent evaluation, the NRC staff determined that the licensee was not required to report this regulatory commitment change. The NRC staff found this acceptable since the licensee had conservatively reported this change to the NRC.
During the audit, the licensee's staff provided the NRC staff with only one regulatory commitment that was revised since the last audit without reporting to the NRC. This commitment was originated in the licensee's reply to a notice of violation, in a letter dated February 23, 1989. This commitment change is captured in the PassPort© database as AR 387054. The original commitment was made to restore compliance with a Technical Specification which required that facility records be retained in accordance with the American National Standard Institute (ANSI) N45.2.9-1974, "Collection, Storage, and Maintenance of Quality Assurance Records." The proper retention time in accordance with the requirements of this ANSI standard is 5 years. However the original commitment stated that a revision to the equipment clearance procedure should be implemented to require the retention of safety-related clearances as QA records (i.e., life time retention). Therefore the original commitment for retaining the clearance for a life time exceeded the applicable ANSI requirements. The NRC staff reviewed the licensee's Regulatory Commitment Change Evaluation, using Attachment 3 of REG-NGGC-0110 procedure. The NRC staff determined that the licensee adequately evaluated and revised this regulatory commitment, and no notification to the NRC was required.
Discussions with BSEP staff confirmed that REG-NGGC-0110 is being adequately implemented at the plant, which further supports the NRC staff's conclusion that regulatory commitments are being revised in accordance with the guidance contained in NEI 99-04. In addition, the NRC staff reviewed documentation from the licensee related to the items discussed above 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.
2.3 Audit Observations and Suggestions During the audit, the NRC staff noticed that:
(1 ) PassPort© database is used for all plant activities. Therefore, unless specific information (such as an AR number) is available, PassPort© is not a friendly tool for searching and identifying regulatory commitments applicable to the NRC.
(2) Most of the time, an AR for tracking a regulatory commitment was generated after the NRC approval of the licensing action that contained a commitment. As such, no AR was generated in the PassPort© database, if the regulatory commitment completion date was the same as or before the licensing action was approved.
During the audit, the NRC staff and the BSEP licensing personnel discussed ways to improve efficiency and traceability of new regulatory commitments and managing changes to the ongoing regulatory commitments in the PassPort© database. The following items were suggested:
- 6 (1) AR initiation -Initiate an AR in the PassPort© database for any regulatory commitment that is submitted to the NRC, as soon as it is officially submitted.
(2) Implementation Dates - clearly document in the AR both the regulatory commitment due date and completion date. Make sure that the AR completion date matches the completion date in the closure documentation.
- 3) Regulatory commitment changes - Ensure a new AR is opened for any regulatory commitment changes. Also, retain completed REG-NGGC-0110, Attachment 3 documentation until the next NRC's commitment audit (although not discussed in NEI 99-04).
As an additional observation, the licensee is planning to periodically run a PassPort© report to maintain awareness of upcoming regulatory commitment due dates and ensure due dates are met or appropriately reported to the NRC.
3.0 CONCLUSION
The NRC staff concludes that based on the above audit: (1) BSEP has implemented NRC commitments in a timely manner, and (2) BSEP has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Bill Murray Licensing Engineer Mark Turkal Licensing Engineer, as needed Lee Grzeck Licensing Engineer, as needed Annette Pope Supervisor - Licensing and Regulatory Programs Principal Contributor: Farideh E. Saba
Attachment:
Summary of Audit Results
SUMMARY
OF AUDIT RESULTS IMPLEMENTATION OF COMMITMENTS:
No. Category Letter Date Commitment Scheduled Date Action Request Completion Date and No. No. Method Assignment No.
1 Pursuant to May 1, 2006 Based on satisfactory tests results from Pursuant to 10 AR190245 The necessary Title 10 of the PE&RAS-05-066 applicable pressure drop tests of the CFR 20.1705 AR317S06 training materials Code of various combinations of hose lengths and were prepared Federal number and types of connections that are (effective May 3, Regulations representative of those anticipated to be 2009) and plant (10 CFR) used, Carolina Power & Light Company procedures were 20.1705 (CP&L) will incorporate specific instructions updated into the respiratory protection program to (February 19, ensure that the air is supplied to the suit 2009).
inlet consistent with the conditions for which this equipment was certified 2 Generic Letter May 9, 200S CP&L will complete detailed walkdowns and Prior to startup AR2S3500-01 Walkdowns were (GL) 200S-01 BSEP OS-0060 any necessary ultrasonic examinations of from the B219R1 completed by inaccessible piping at locations potentially refueling outage, April 10, 2009.
susceptible to gas accumulation for systems currently within the scope of Generic Letter (GL) scheduled to 200S-01 for Brunswick Steam Electric Plant begin on (BSEP) Unit 2, prior to startup from the next February 2S, refueling outage (Le., B219R1). 2009.
~
1 AR 190245 is superseded AR317S06.
Attachment
-2 No. Category Letter Date Commitment Scheduled Date Action Request Completion Date and No. No. Method Assignment No.
3 GL200S-01 May 9, 200S CP&L will submit a supplemental response Within 90 days AR2S3500-02 Supplemental BSEP OS-0060 to GL 200S-01 within 90 days following the following the response completion of the B219R 1 refueling outage. completion of the submitted on The supplemental response will describe B219R1 refueling July 27, 2009, by any changes to the 9-month response outage, currently BSEP 09-0079 resulting from walkdowns and ultrasonic scheduled to end letter.
examination of inaccessible BSEP Unit 2 on April 11 ,
pipinQ. 2009.
4 GL200S-01 May 9, 200S CP&L will complete any necessary Prior to startup AR2S3500-03 All activities were BSEP OS-0060 ultrasonic examinations or additional from the B11SR1 completed during inspections of inaccessible piping at refueling outage, the outage.
locations potentially susceptible to gas currently However, AR was accumulation for systems within the scope scheduled to closed (shown of GL 200S-01 for BSEP Unit 1 prior to begin on completed) on startup from the next refueling outage (Le., February 27, June 04, 2010.
BI1SR1). 2010.
5 GL200S-01 May 9, 200S CP&L will submit a supplemental response Within 90 days AR2S3500-04 BSEP 10-0089 BSEP 08-0060 to GL 200S-01 within 90 days following the following the letter dated completion of the B 11SR 1 refueling outage. completion of the July 22, 2010.
The supplemental response will describe B 11SRI refueling any changes to the nine-month response outage, currently resulting from walkdowns and ultrasonic scheduled to end examination of inaccessible BSEP Unit 1 on April 5, 2010.
piping.
6 Amendment June 19, 200S CP&L will establish the Technical To be 266789-08 Incorporated by TS BSEP 08-0083 Specification (TS) Bases for TS B 3.1.3 and implemented with Bases Revs 63 TSC-200S-03 TS B 3.1.4 consistent with those provided in implementation (Unit 1) and 60 Enclosure 5. of the (Unit 2) on amendment. January 14, 2009.
Submitted to the NRC by letter dated October 12, 2010, BSEP 10 0113.
- 3 No. Category Letter Date Commitment Scheduled Date Action Request Completion Date*
and No. No. Method Assignment No.
7 Amendment October 6, 2008 Removal of the plant-specific TS This commitment 288091-20 Amendment PE&RAS-08-037 requirements will be performed concurrently will be completed implemented by with the implementation of the 10 CFR no later than August 17, 2009.
Part 26, Subpart I requirements. October 1, 2009.
8 GL 2008-01 October 10, 2008 CP&L will submit a license amendment Within 9 months 295801-01 Awaiting NRC BSEP 08-0137 request based on the approved TSTF following NRC approval of TSTF.
related to the potential for unacceptable gas approval of the accumulation, if deemed necessary. TSTF.
-4 No. Category Letter Date Commitment Scheduled Date Action Request Completion Date and No. No. Method Assignment No.
9 GL 2008-01 October 10, 2008 CP&L will install new vent valves in the Unit Installation of the 295801-21 Implementing Work BSEP 08-0137 1 and Unit 2 high pressure coolant injection new Unit 1 vent 295801-22 Orders listed in (HPCI), residual heat removal (RHR), and valves and 295801-23 295801-21.
core spray (CS) systems in locations which associated 295801-24 were determined based on analyses of procedure Implementing Work walkdown and ultrasonic testing (UT) changes will be Orders listed in examination results completed to date. completed prior 295801-22.
to startup from CP&L will revise the following fill and vent the B118R1 295801-23: 10P procedures for the HPCI, RHR, and CS refueling outage, 17 Rev 100, 101, systems to incorporate the addition of new currently and 102 (RHR),
vent valves. scheduled to 10P-18 Rev 49 begin on and 50 (CS), 10P 1/20P-19, "High Pressure Coolant Injection February 27, 19 Rev 78 (HPCI)
System Operating Procedure" 2010. Installation 1/20P-17, "Residual Heat Removal System of the new Unit 2 295801-24: 20P Operating Procedure" vents valves and 19 Rev 116 1/20P- 18, "Core Spray System Operating associated (HPCI), 20P-17 Procedure" procedure Rev 152 (RHR),
changes will be 20P-18 Rev 63 com pleted prior (CS) to startup from the B219R1 All activities were refueling outage, completed during currently the outage.
scheduled to begin on February 28, 2009.
- 5 No. Category Letter Date Commitment Scheduled Date Action Request Completion Date-and No. No. Method Assignment No.
10 GL 2008-01 October 10, 2008 CP&L will revise the following fill and vent These revisions 295801-25 295801-25: 10P BSEP 08-0137 procedures for the HPCI, RHR, and CS will be completed 295801-26 19 Rev 74 (HPCI),
systems to: (1) incorporate use of additional by April 11, 2009 10P-17 Rev 97 existing vents as required, in the proper for Unit 1. (RHR),10P-18 sequence, and (2) fill and vent instrument Rev 48 (CS) lines, as required. These revisions will be completed 295801-26: 2OP 1/20P-19, "High Pressure Coolant Injection prior to the 19Rev116 System Operating Procedure" 1/20P-17, system being (HPCI),20P-17 "Residual Heat Removal System Operating restored to Rev 152 (RHR),
Procedure" 1/20P- 18, "Core Spray System service during 20P-18 Rev 63 Operating Procedure" the B219R1 (CS) refueling outage for Unit 2. All activities were completed during the outage.
11 GL 2008-01 October 10, 2008 CP&L will revise the following BSEP TS These 295801-27 OPT-09.3A Rev 26, BSEP 08-0137 monthly surveillance testing procedures for procedures will OPT-07.1.8 Rev the GL 2008-01 subject systems to: (1) be revised by 25, OPT-08.1.3B require entry into the corrective action completion of the Rev 9, OPT-program when excessive gas accumulation B219R1 outage, 08.1.3A Rev 5 is found to address operability currently considerations and (2) revise solid stream scheduled to All activities were acceptance criterion to "solid stream for at begin on completed during least 2 minutes." February 28, the outage.
OPT-09.3a, "HPCI System Component 2009.
Test" OPT-08.1.3a, "LPCI/RHR System Component lest - Loop A" OPT-08.1 .3b, "LPCIIRHR System Component Test - Loop B" OPT-07.1.8, "Core Spray System Component T~§lt_"_ -
-6 No. Category Letter Date Commitment Scheduled Date Action Request Completion Date and No. No. Method Assignment No.
12 GL 2008-01 October 10, 2008 CP&L will revise the following BSEP TS These 295801-28 OPT-09.2 Rev 129 BSEP 08-0137 quarterly surveillance testing procedures for procedures will (HPCI), OPT the GL 2008-01 subject systems to ensure be revised by 08.2.2C Rev 71, that monthly surveillance testing completion of the OPT-08.2.2B Rev performance occurs prior to or as part of the B219R1 outage, 84,OPT-07.2.4B quarterly surveillance. currently Rev 62, OPT OPT-09.2, "HPCI System Operability Test" scheduled to 07.2.4B Rev 61 OPT-OS.2.2c, "LPCI/RHR System begin on Operability Test - Loop A" OPT-08.2.2b, February 2S, All activities were "LPCI/RHR System Operability Test- 2009. completed during Loop B" the outage.
OPT-07.2.4a, "Core Spray System Operability Test - Loop A" OPT-07.2.4b, "Core Spray System Operability Test - Loop B" 13 Amendment July 23, 2009 Local leakage rate testing of the new X-2 Prior to startup NoAR Withdrawn by the BSEP 09-0077 containment penetration metallic liner welds following the licensee on TSC-2009-07 associated with installation of a replacement B11SR1outage. September 3, 2009 X-2 penetration sleeve will be performed. and acknowledged by the NRC on September 18, 2009.
14 Amendment July 23, 2009 As part of the X-2 containment penetration Prior to startu p NoAR Withdrawn by the BSEP 09-0077 replacement, a 100 percent examination following the licensee on TSC-2009-07 surface (i.e., liquid penetrant or magnetic B11SR1 outage. September 3,2009 particle examination) and spot volumetric and acknowledged (i.e., UT or radiography) will be performed by the NRC on on the metallic liner repair welds. September 18, 2009.
-7 No. Category Letter Date C.ommitment Scheduled Date Action Request Completion Date and No. No. Method Assignment No.
15 Amendment July 23, 2009 As part of the X-2 containment penetration Prior to startup NoAR Withdrawn by the BSEP 09-0077 replacement, a 100 percent VT-I following the licensee on TSC-2009-07 examination of the accessible surfaces of B118R1 outage. September 3, 2009 the new penetration sleeve and and acknowledged containment liner affected by the repair will by the NRC on be conducted. September 18, 2009.
16 Emergency September 29, Submit the FEMA approval letter of the Within 30 days of NOAR By letter BSEP 09 Plan Changes 2009 revised EPZ zone descriptions and revised FEMA approval 0214 dated BSEP 09-0089 zone descriptions that are consistent with of the updated November 11, those approved by FEMA. zone 2009.
descriptions.
(FEMA's letter dated October 30, 2009) 17 Cyber September 23, CP&L and Florida Power Corporation (FPC) On or before 366703 Commitment Security Plan 2010 will supplement Section 2.1, "Scope and November 30, revised by letter RA-10-025 Purpose," of the CP&L and FPC Cyber 2010 dated Security Plan. Section 2.1 will be amended November 30, to clarify the balance of plant (BOP) 2010, RA-10-026.
structures, systems and components (SSCs) that will be included in the scope of the cyber security program.
18 Cyber November 18, The BSEP Cyber Security Plan will be According to 366703 One commitment Security Plan 2009 implemented in accordance with the implementation was completed by BSEP 09-0116 implementation schedule provided in schedule. July 8, 2010. Three Enclosure 2 and, therefore, be fully other commitments implemented within 36 months of the date superseded by the of NRC approval of the Cyber Security Plan. commitments being tracked via
,---- 471149.
- 8 No. Category Letter Date Commitment Scheduled Date Action Request Completion Date and No. No. Method Assignment No.
19 Notice of November 4,2010 Full compliance will be complete, by January 15, 2011 431635 Background Violation BSEP 10-0124 January 15, 2011, based upon completion investigations of the background investigations that are completed as being reperformed for those DZ Atlantic documented in AR employees currently badged at Progress 431635-01.
Energy nuclear sites, as stated in Section 3 of written response to the Notice of Violation Completed by EA-10-032. November 19, 2010.
20 Cyber November 30, CP&L and FPC will amend the Carolina On or before 366703 Commitment Security Plan 2010 Power & Light Company and Florida Power November 30, addressed by RA-10-026 Corporation Cyber Security Pan, as 2010 response in letter needed, to clarify that BOP SSCs are within dated April 7, the scope of the cyber security program 2011, RA-11-011, consistent with the NRC's yet to be issued RAI3.
position on BOP cyber security jurisdiction.
The timing of the change will be consistent with a schedule to be provided by the NRC staff.
- 9
,-~~~~~~ ~ ~ ~
No. Category Letter Date Commitment Scheduled Date Action Request Completion Date and No. No. Method Assignment No.
21 Exemption December 16, BSEP will maintain the following information 30 days after 463454" Incorporated into 2010 in site procedures: exemption OAI-68 Rev 38.
- The entry conditions necessary to approval.
sequester site personnel, Exemption was consistent with the conditions approved on specified in the exemption request. June 2, 2011.
- Provisions for ensuring that Regulatory personnel who are not performing Commitment was duties are provided an opportunity, completed by as well as accommodations, for June 30, 2011.
restorative rest.
- The exit conditions for departure from the exemption, consistent with the conditions specified in the exemption request.
22 Amendment March 16,2011 When using AREVA Topical Report BAW Upon 459973-1 for Ongoing.
BSEP 11-0031 10247PA, "Realistic Thermal-Mechanical implementation Unit 1 The licensee TSC-2010-02 Fuel Rod Methodology for Boiling Water of the Unit 1 and 459973-2 for closes this AR after Reactors," Revision 0, April 2008, to Unit 2 license Unit2 completion of the determine core operating limits, the fuel amendments referenced cycles cladding peak oxide thickness calculated by authorizing the in this regulatory the RODEX4 corrosion model will be limited incorporation of commitment and to less than the proprietary value defined in AREVA Topical initiates a new AR Section 2.2 of AREVA Report ANP-2992P, Report for the subsequent Revision 0, AREVA Response to Additional BAW-10247PA cycles.
RAI on the BSEP RODEX4 License into TS S.6.S.b.
Amendment Request (LAR). ----------
2 This regulatory commitment was required for approval of emergency plan changes.
- 10
-~~~~-~~
No. Category Letter Date Commitment Scheduled Date Action Request Completion Date and No. No. - Method Assignment No.
23 Cyber April 7, 2011 Security-related information. Security-related 471149" Cyber Security Security Plan RA-1 1-011 information. Plan license amendment issued July 25, 2011.
Commitment tracking assignments issued August 3, 2011 via NTM 471149.
24 Enforcement June 29,2011 BSEP, Unit Nos. 1 and 2 will submit aLAR September 30, 477582 Open Discretion RA-11-019 for transitioning to NFPA 805. The LAR will 2012 include a plant-wide assessment to identify fire areas and fire hazards and evaluate compliance with the existing BSEP, Unit 1 and 2 fire protection licensing basis. This assessment will be performed in accordance with NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)." -~~-~~
3 AR was initiated prior to approval of this licensing action.
February 28, 2012 Mr. Michael J. Annacone, Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461 SUB~IECT: BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEIVIENT OF REGULATORY COMMITMENTS (TAC NOS. ME5438 AND ME5439)
Dear Mr. Annacone:
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute 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 Carolina Power and Light Company's commitment management program was performed at the plant site during the period of September 13 and 14, 2011. Based on the audit, the NRC staff concluded that (1) Brunswick Steam Electric Plant (BSEP), Units 1 and 2 has implemented NRC commitments on a timely basis, and (2) BSEP has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, Ira!
Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324
Enclosure:
Audit Report cc: Distribution via ListServ DISTRIBUTION:
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