ML13022A401

Audit of the Licensee'S Management of Regulatory Commitments

ML13022A401
Person / Time
Site:	Watts Bar
Issue date:	02/07/2013
From:	Justin Poole Plant Licensing Branch II
To:	James Shea, Skaggs M Tennessee Valley Authority
Poole, Justin
References
TAC ME9613, TAC ME9614
Download: ML13022A401 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 7,2013 Mr. Michael D. Skaggs Mr. Joseph W. Shea Senior Vice President Vice President, Nuclear Licensing Nuclear Construction Tennessee Valley Authority Tennessee Valley Authority Lookout Place 3R Lookout Place 6A 1101 Market Street 1101 Market Street Chattanooga, TN 37402-2801 Chattanooga, TN 37402-2801 SUBJECT WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. ME9613 AND ME9614)

Dear Mr. Skaggs and Mr. Shea:

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlllng regulatory commitments. RIS 2000-17 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 regulatory commitments are being effectively implemented.

An audit of Watts Bar Nuclear Plant's (WBN's) commitment management program was performed at the WBN site and the corporate office in Chattanooga, Tennessee during the period November 5 - 9,2012. The NRC staff concludes, based on the audit, that (1) WBN has

-2 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.

Sincerely,

~~--

~.... Justin C. Poole, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-390 and 50-391

Enclosure:

Audit Report cc: Listserv

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS WAITS BAR NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-390 AND 50-391

1.0 INTRODUCTION AND BACKGROUND

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 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. 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.

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 regulatory commitments are being effectively implemented. An audit of the Watts Bar Nuclear Plant (WBN) commitment management program was performed at the WBN site and corporate office in Chattanooga, Tennessee during the period November 5 - 9, 2012. The audit reviewed commitments made since the previous audit on October 21, 2009.

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.).

2.0 AUDIT PROCEDURE AND RESULTS The audit consisted of three major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, (2) verification of the licensee's program for managing changes to NRC commitments and (3) verification that all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews.

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 Enclosure

-2 program for future implementation. 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.

2.1.1 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 Agencywide Document Access and Management System 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 provides details of the audit and its results.

The NRC staff sampled 76 commitments between the two units and all sampled commitments were identified in the licensee's commitment tracking system.

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. Since the previous audit conducted in October 2009, the process used at WBN changed from Standard Programs and Processes (SPP) 3.3, "NRC Commitment Management," which the staff found to have requirements consistent with the guidance contained in NEI 99-04, to Nuclear Power Group Standard Programs and Processes

-3 (NPG-SPP) 3.3 "NRC Commitment Management." As part of this audit, the NRC staff reviewed the differences between the two procedures. The audit also 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. In addition, the NRC staff reviewed the self-assessments (Numbers CRP-LlC-F09-002 and CRP-LlC-S-12-002) of the implementation effectiveness of NPG-SPP 3.3 by TVA Nuclear Power Group (Corporate) Licensing in April 2009 and September 2012.

2.2.1 Audit Results The attached Audit Summary also provides details of this portion of the audit and its results.

The NRC staff found one example where TVA had provided the necessary information to the staff and stated that the commitment was considered closed but during the audit, it was found to be open in licensee's commitment tracking system. When informed, TVA staff corrected the error. The NRC staff has no further questions regarding this item. The NRC staff found that NPG-SPP 3.3 requirements are consistent with the guidance contained in NEI 99-04.

2.3 Review to Identify Misapplied Commitments The commitments reviewed for this audit were also evaluated to determine if they had been misapplied. A commitment is considered to be misapplied if the action comprising the commitment was relied on by the NRC staff in making a regulatory decision such as a finding of public health and safety in an NRC safety evaluation associated with a licensing action.

Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (i.e., commitments used to ensure safety).

Each of the commitments selected for the audit sample were reviewed to determine if any had been misapplied. None of the commitments selected for the audit sample were determined to be misapplied.

2.3.1 Review of Safety Evaluation Reports for Licensing Actions since the Last Audit to Determine if They Are Properly Captured as Commitments or Obligations In addition to the commitments selected for the audit sample, all license amendment, exemption and relief request safety evaluations that have been issued for WBN since the last audit were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above. The evaluation concluded that none of these documents contained any misapplied commitments.

3.0 CONCLUSION

The NRC staff concludes, based on the above audit, that (1) WBN has implemented NRC commitments on a timely basis, and (2) has implemented an effective program for managing NRC commitment changes.

-4 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Geoff Cook - TVA Corporate Licensing Criss Riedl- TVA Corporate Licensing Donna Guinn - Watts Bar Unit 1 Licensing Rusty Stroud - Watts Bar Unit 1 Licensing Beverly Duckett - Watts Bar Unit 1 Licensing Gordon Arent - Watts Bar Unit 2 Licensing Tommy Elton - Watts Bar Unit 2 Licensing Principal Contributors: Andrew Hon Justin Poole Date: February 7, 2013

Attachment:

Summary of Audit Results

AUDIT

SUMMARY

IMPLEMENTATION OF COMMITMENTS:

The following commitment samples were reviewed:

Description Licensee ADAMS Comments No. Reference Unit 1 Full compliance with 10293031 ML093160116 This was closed upon 10CFR73.55(i)(4)(A)-(D), the installation of a 10CFR73.55(e)(1)(C) and new remote 10CFR73.55(i)(3)(vii) for WBN monitoring system, a by September 24, 2012. new access control system and a new uninterruptible power supply by September 21,2012.

Revise UFSAR Section 5.2.1.5 111952889 ML080420477 This was closed upon and Table 5.2-2 to prohibit the UFSAR Amendment performance of a turbine roll test 9 submitted to NRC or a hydrostatic test transient. on November 21, 2011. In addition, site procedure 1-SI-8 was updated to include the changes.

Issue and initially perform a 113636603 ML12171A053 This was closed upon procedure for a semi-annual procedures issued inspection of the compensatory and performed by measure for flood protection of August 30, 2012.

the WBN-1 Thermal Barrier Booster pump and motors by August 31, 2012.

Issue and initially perform a 113637349 ML12171A053 This was closed upon procedure for a semi-annual procedures issued inspection of the temporary and performed by HESCO flood barriers installed August 29, 2012.

at four dams by August 31, 2012.

Submitting a LAR to update 113636334 ML12171A053 This was closed upon WBN-1 UFSAR - hydrology. TVA submittal of the LAR on July 19, 2012.

Administrative commitment- 113194918 This was closed upon Implement Design Change to the Design Change remove Min-K insulation during Package closure the Fall 2012 Refueling Outage. after the Refueling Outage in October 2012.

Attachment

- 2

, Administrative commitment 113194886 This was closed upon Implement Design Change to the Design Change replace RHR sump strainer Package closure plenum cover plate with larger after the Refueling orifice size during the Fall 2012 Outage in October Refueling Outage. 2012.

Administrative commitment to 112576642 This was closed upon industry's Ground Water WBN Chemistry Protection Initiative (NEI 07-07) identified four identified actions to improve procedures that TVA's management and implemented WBN's response to the inadvertent Ground Water release of radioactive Protection Program substances. These releases on September 23, may result in low but detectable 2011.

levels of plant-related material in subsurface soils and water.

Submit WBN fire protection 112946586 ML11329A089 This was changed by report with rev bars by July 1, a letter dated March 2012. 13,2012.

Technical Specification (TS) 112071014 ML100570414 This commitment Change - Main Control Room was cancelled on Chiller Completion Time May 13, 2012, by Extension one time during the WBN site because replacement of MCR chillers the chiller during March 1, 2011 and April replacement was 30,2012. TVA committed four deferred until compensatory actions during the required parts could replacement of the MCR chillers be procured.

to minimize the probability of Corporate licensing total loss of capability. decided to resubmit LAR at a later date when the new replacement schedule is finalize by the site. Since the condition for the commitment was not materialized during the specified period, a notification of the change was determined to be not applicable.

-3 Unit 2 Submittal of Fire Protection 111331309 ML101970311 This was closed upon' Report (FPR) by December 17, submittal of letter 2010 dated December 18, I 2010.

Provide markup, description, and 111331313 ML101970311 This was closed upon

• justification of changes made to submittal of letter the FPR since NRC approval by dated August 30, August 30, 2010. 2010.

Submit portions of FPR not 111331314 ML101970311 This was closed upon affected by operation of Unit 2 submittal of letter by August 6, 2010. dated August 9, 2010.

Provide a description of how 111331316 ML101970311 This was closed upon safe shutdown is ensured for submittal of letter each Multiple Spurious dated August 20, Operation scenario by 2010. This letter August 20, 2010. opened up two additional commitments (TVA 111905993 and 111905994) which remain open.

Provide the baseline list of 111331318 ML101970311 This was closed upon operator manual actions by submittal of letter August 6, 2010. dated August 9, 2010.

TVA will provide the NRC with 111032952 ML101230264 This remains open the latest revised information to due to the last part of the Radiological Emergency the commitment.

Plan (REP). If changes are TVA has submitted, made after NRC review of the and staff has plan, TVA will provide updates of reviewed the REP, all changes made to the WBN but a final version will Unit 1/2. be sent in just prior to fuel load activating the plan for duel unit operation.

REP - calculations verified and 111032960 ML101230264 This was closed upon submitted. submittal of letter dated October 11 ,

2010.

REP - revise bases to reflect the 111032968 ML101230264 This was closed upon correct threshold value. submittal of letter dated October 11 ,

2010.

REP - revise the language to 111032975 ML101230264 This was closed u clarify on the intent of the submittal of letter

-4 threshold. dated October 11, 2010.

REP-TVA will evaluate adding 111032992 ML101230264 This was closed upon information to the basis for the submittal of letter applicable Initiating Condition dated October 11, (lC). 2010.

REP-TVA will correct the  ! 1110333001 ML101230264 This was closed upon example designators to be dual submittal of letter unit specific. dated October 11,

.2010.

REP-TVA will remove 111033009 ML101230264 I This was closed upon designators (Units 1 & 2 and

• submittal of letter

. Unit 1 or 2) for Additional dated October 11 ,

Equipment Building, CST, and 2010.

RWST.

REP-TVA will remove 111033029 ML101230264 This was closed upon designators (Units 1 & 2 and submittal of letter Unit 1 or 2) for reactor building. dated October 11 ,

2010.

REP-TVA will provide the NRC 111033038 ML101230264 Listed as OPEN in staff with an updated the database but in classification scheme that reviewing the letter reflects these changes for WBN dated October 11 ,

Unit 2. 2010, the information was provided and TVA stated that the item was closed.

TVA missed updating their database. TVA reviewed the documents, agreed the commitment should be closed, and updated the database.

REP-TVA will remove 111033050 ML101230264 This was closed upon

• designators (Units 1 & 2 and submittal of letter

• Unit 1 or 2). dated October 11, 2010 .

REP-TVA will revise IC 6.2.A 111033057

• ML101230264 This was closed upon and 6.2.U to be consistent with submittal of letter the Mode 1-4 ICs. dated October 11, 2010 .

REP-TVA agrees to revise 111033068 ML101230264

• This was closed upon specific wording. submittal of letter dated October 11 ,

I 2010.

-5 REP - (a) Plant data displays 111033086 ML101230264 This item remains will be updated as necessary to Open due to parts (b) include WBN Unit 2. (b) TVA will and (c) of the update dose assessment models commitment. Part (a) to provide capabilities for has been completed.

assessing releases from both units. (c) TVA will review needed assessment capability to ensure strategies and guidance reflect the addition of WBN Unit 2.

TVA commits to incorporate the 111017593 ML101450242 This was closed instrumentation setpoint based on the methodology that is consistent information being with WBN Unit 2 Licensing provided in Bases into the WBN Unit 2 Amendment 100 on FSAR no later than Amendment September 1, 2010.

100.

Amendment 101 to the Unit 2 111364245 ML102510580 This was closed FSAR will implement changes as based on the noted. information being provided in Amendment 101 on October 29, 2010.

Calculation WCG-1-2010 will be 111880118 ML102510580 This was closed revised to include the Unit 2 based on a revision Polar Crane as a Single Failure to the stated Proof Equivalent per Chapter 3 calculation to include of NEI 08-05 by October 29, WBN Unit 2.

2010.

The new Unit 2 FSAR Section 111364253 ML102510580 This was closed 3.12 will be submitted to the based on the NRC by November 24,2010. information being provided in Amendment 103 on March 15, 2011.

Individual Plant Examination 111332410 ML102280585 This was closed (lPE) - TVA will respond to NRC based on the Request for Additional information being Information (RAI) 14 by provided in letter October 29, 2010. dated January 31, 2011.

IPE - Prior to fuel load, TVA will 111626075 ML102280585 This remains Open.

revise 125V DC system top to correctly model board failure IPE - Prior to fuel load, TVA will 111626093 ML102280585 This remains Open.

perform a full review of the database after all model changes to address findings are

-6 complete IPE - Prior to fuel load, TVA will 111626105 ML102280585 This remains Open.

update the database to address CDE 650 and 651.

IPE - Prior to fuel load, TVA will 111626113 ML102280585 This remains Open.

update the type codes for the motor driven auxiliary feedwater pumps.

IPE - Prior to fuel load, TVA will 111626120 ML102280585 This remains Open.

fully resolve F&O 4-3.

TVA will change the current 111889786 ML101790399 This commitment Unit 2 clevis insert bolts to the was closed based on latest design, which uses an TVA's withdrawal of X-750 alloy prior to Unit 2 the commitment.

operation. TVA withdrew the commitment by letter dated April 21, 2011, ML111110513. The NRC staff asked follow-up RAls based on this withdrawal and will revise its Safety Evaluation Report in the next supplement.

Amendment 102 will include a 111761551 ML103480692 This was closed revised discussion in Section based on the 9.2.2.4. information being provided in Amendment 102 on December 17, 2010.

Amendment 102 will remove 111761556 ML103480692 This was closed historical "Unit 1 Only Operation" based on the statements. information being provided in Amendment 102 on December 17, 2010.

Amendment 102 will revise 111761560 ML103480692 This was closed Section 9.2.2.4 to be consistent based on the with Section 9.2.2.2. information being provided in Amendment 102 on December 17, 2010.

Amendment 102 will revise 111761566 ML103480692 This was closed Section 9.2.2 to better describe based on the the CCS alignment for dual unit information being operation. provided in Amendment 102 on

-7 December 17, 2010.

TVA will revise response 111902242 ML103480692 This item remains procedures (ES-1.3, "Transfer to Open as the Containment Sump") to specify procedure has not clear criteria for taking actions yet be updated.

from the control room.

TVA will revise the System 67 111902277 ML103480692 This item remains System Description and Open.

applicable procedures to accomplish the above activities.

Amendment 102 will revise 111761573 ML103480692 This was closed Section 10.4.9.2 to remove the based on the discussion regarding General information being Design Criteria 5. provided in Amendment 102 on December 17, 2010.

Amendment 102 will revise 111761581 ML103480692 This was closed Table 10.4.6. based on the information being provided in Amendment 102 on December 17, 2010.

Amendment 102 will revise 111761614 ML103480692 This was closed Section 10.4.9.3 based on the information being provided in Amendment 102 on December 17, 2010.

Amendment 102 will add a test 111761623 ML103480692 This was closed requirement to Table 14.2-1, based on the Sheet 13. information being provided in Amendment 102 on December 17, 2010.

Amendment 102 will revise 111761634 IVIL103480692 This was closed Table 15.5-14. based on the information being provided in Amendment 102 on December 17, 2010.

Amendment 103 will update 111762411 ML103480692 This was closed values in the FSAR. based on the information being provided in Amendment 103 on March 15, 2011.

Non-proprietary version of 111902413 ML103480692 This was closed to this letter will be based on the

- 8 provided two weeks after receipt information provided from Westinghouse. in letter dated June 27,2012.

Future amendment to the Unit 2 111637074 ML103200144 This was closed FSAR will correct titles for the X based on the axes on Chapter 15 tables information being provided in Amendment 103 on March 15, 2011.

Future amendment to the Unit 2 111637079 ML103200144 This was closed FSAR will provide legible version based on the of Figure 15.2-11. . information being provided in Amendment 103 on March 15, 2011.

TVA will make editorial 111637090 ML103200144 This was closed corrections in a future based on the amendment to the Unit 2 FSAR information being in Chapter 3. provided in Amendment 101 on October 29, 2010.

Future amendment to the Unit 2 111637092 ML103200144 This was closed FSAR will remove reference to based on the Code Case 1423-2. information being provided in Amendment 101 on October 29, 2010.

FPR will be provided by 112068454 ML110770448 This commitment March 16,2011 except for 112068464 was tracked by 2 Part V which will be provided by items in TVA's April 29, 2011. database. The first for submitting all but Part V by March 16, 2011. The second for providing Part V by April 29, 2011.

Both of these items were closed based on the information being submitted to the staff on March 16, 2011 and May 18, 2011.

Provide January 14, 2011 112068476 ML110770448 This was closed version of the FPR with revision based on the bars. Justifications for changes information provided not directly related to Unit 2 in letter dated operation will be provided. March 31, 2011.

- 9 I Provide digital copy of Revision 112068495 ML110770448 This was closed 41 to the FPR. based on the information provided in letter dated March 16, 2011.

TVA will provide side-by-side 112068507 ML110770448 This was closed comparison between January based on the 14, 2011 version of the FPR and information provided the one to be submitted on in letter dated March 16, 2011. March 16,2011.

Provide updated Figures 11-1A 112068520 ML110770448 This was closed thru 11-26A by March 16, 2011. based on the information provided in letter dated March 16, 2011.

Figures representing the as- 112068531 ML110770448 This item remains constructed plant configuration open as construction will be provided after is not yet complete.

construction completion.

Response to RAI FPR V-1 will 112068537 ML110770448 This was closed be provided by March 25,2011. based on the information provided in letter dated March 31, 2011.

Response to RAI FPR V-2 will 112068570 ML110770448 This was closed be provided by April 29,2011.

• based on the

• information provided in letter dated July 1, 2011.

After performing final walkdowns 112068578 ML110770448 This item remains as prescribed in the FPR, TVA open as construction will submit the results to the is ongoing and the NRC. walkdowns have not occurred.

The requirement for a portable 112068588 ML110770448 This was closed lantern will be evaluated during based on the the Unit 2 walkdowns of operator information provided manual actions. in letter dated May 18, 2011.

The FPR will be revised to clarify 112068737 ML110770448 This was closed which Modes of operation a based on the reduction specified in RAI FPR information provided 11-8 is applicable to. in letter dated May 18,2011.

• Barriers separating the Unit 2 112068748 ML110770448 This item remains

• Reactor Building from the open.

Refueling Floor will be configured and controlled the

- 10 same as Unit 1 Reactor Building Equipment Hatch.

TVA will issue the as- 111903011 ML103570374 TVA first revised this constructed FPR for Units 1 and commitment in a 2 by October 1, 2011. letter dated August 15, 2011, which stated a new due date of July 1, 2012. This commitment was then closed when a letter dated March 13, 2012, stated that the schedule for the as-constructed FPR would be sent to the NRC when it was available (TVA 113315590). TVA then closed this commitment to a new commitment made in letter dated April 26, 2012 (TVA 113461862) saying that the as-constructed would be submitted to the NRC no later than October 15, 2014.

If the FPR re-analysis 111903056 ML103570374 This was closed determines that any other fire based on the areas are affected, TVA will information provided submit the necessary revisions in letter dated by February 28, 2011. March 16, 2011.

TVA will fix the administrative 111831467 ML103570374 This was closed errors in the FPR and re-submit based on the Parts V and VI by January 14, information provided 2011. in letter dated January 14, 2011.

An Owners Summary Report 112047866 ML102850246 TVA closed this shall be issued within 90 days commitment and following Unit 2 commercial opened three new operation for those repairs or commitments (TVA replacements, if any, which were 112687714, performed under Section XI on 112687720, and Unit 2 prior to commercial 112687727) based operation. on a letter dated

- 11 September 1, 2011.

All three of these appropriately remain open.

TVA will report the results of the 112179285 ML11112A137 This item was closed hydrology analysis without use based on the of sand baskets or the seismic information in letter test of sand baskets to the NRC dated October 31, by October 31, 2011. 2011. This letter created a new commitment (TVA 112870791) to update the FSAR, which was closed based on submittal of Amendment 107.

TVA will provide an update of 112179286 ML11112A137 This item was closed the WBN 2 FSAR to describe the based on the long-term stability analysis information in letter methodology following the dated September 6, completion of the finite element 2012. This letter analyses by August 31,2012. created a new commitment (TVA 113880166) stating that TVA will design and implement modifications for Cherokee and Douglas Dams prior to WBN 2 startup.

This commitment remains open.

TVA will continue to inspect and 112179287 ML11112A137 This item remains maintain the baskets as required open.

until the implementation of the permanent solution at all four dams.

TVA will provide an update 112179288 ML11112A137 This was closed describing the increased height based on the at Fort Loudoun, Cherokee, information being Watts Bar, and Tellico dams as provided in the current licensing basis for Amendment 104 on WBN 2 in Amendment 104. June 3, 2011.

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