ML13329A350

Audit of the Licensees Management of Regulatory Commitments

ML13329A350
Person / Time
Site:	Browns Ferry
Issue date:	04/07/2014
From:	Farideh Saba Plant Licensing Branch II
To:	James Shea Tennessee Valley Authority
Saba F NRR/DORL 301-415-1447
References
TAC MF2412, TAC MF2413, TAC MF2414
Download: ML13329A350 (55)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Joseph W. Shea Vice President - Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801 April 7, 2014

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MF2412, MF2413, AND MF2414)

Dear 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 controlling regulatory commitments. RIS 2000-17 encouraged licensees to use the NEI 99-04 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. Prior to October 31, 2008, offsite evaluations of the commitment management were being performed by the NRC staff during the review of the actions for the restart of Browns Ferry Nuclear Plant (BFN) Unit 1 and other licensing actions. Therefore, it was determined that the offsite evaluations of these activities met the instructions of LIC-1 05 for regulatory requirements at BFN until October 31, 2008. As such, this audit was the first onsite audit since issuance of LIC-1 05 at the BFN.

An audit of the Browns Ferry commitment management program was performed at the plant site during the period August 13 through 15, 2013. During the audit the NRC staff identified a few errors in tracking of the regulatory commitments and an issue (potential finding) with managing/characterizing a regulatory commitment. Specifically, the NRC staff noted an issue concerning a regulatory commitment change that Tennessee Valley Authority (TVA) reported to the NRC in its letter dated November 30, 2011. During the audit, the NRC staff questioned the TVA's conclusion that only notification was required. Based on the review of the TVA evaluation of the change, the NRC staff believed that, the licensee should have requested the NRC's approval of the change. This issue is currently under review by the NRC's headquarters' staff and the Region II staff as apparent violations.

The NRC staff concludes that, based on the above audit, except for the aforementioned potential finding and other minor issues, (1) the licensee has implemented, or is tracking for future implementation regulatory commitments; (2) the licensee has implemented a program to manage regulatory commitment changes that is consistent with the guidance in NEI 99-04; and

(3) the regulatory commitments are generally characterized as commitments versus obligations.

Overall, the NRC staff believes that TVA has made progress in its commitment management procedures in recent years. Details of the audit are set forth in the enclosed report.

Should you have any questions regarding this letter, please contact me by phone at (301) 415-1447 or via e-mail at Farideh.Saba@nrc.gov.

Docket Nos.: 50-259, 50-260 and 50-296

Enclosure:

Audit Report cc w/encl: Distribution via Listserv Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS BROWNS FERRY NUCLEAR PLANT, UNIT NOS. 1, 2. AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296

1.0 INTRODUCTION AND BACKGROUND

The U.S. Nuclear Regulatory Commission (NRC or the Commission) 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 99-04 guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, report 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 the regulatory commitments are being effectively implemented. Prior to October 31, 2008, offsite evaluations of the commitment management were being performed by the NRC staff during the review of the actions for the restart of Browns Ferry Nuclear Plant (BFN) Unit 1 and other licensing actions. Therefore, it was determined that the offsite evaluations of these activities met the instructions of LIC-1 05 for regulatory requirements at BFN until October 31, 2008.

Consequently, this audit was the first onsite audit since issuance of LIC-1 05 at the BFN site and the audit period covered 5 years instead of the LIC-1 05 instructed 3 years. An audit of the commitment management program covering the period from November 2008 through July 2013 was performed at the plant site during the period of August 13 through 15, 2013.

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 further includes evaluation of the licensee's commitment management procedures as compared to NEI 99-04 guidance, assessment of the licensee's commitment tracking database capabilities, appraisal of Enclosure procedures for changing commitments (for both internal licensee management and communication with the NRC), and verifying the non-existence of misapplied commitments.

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 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 of Licensee's Implementation of NRC Commitments The audit addressed commitments initiated during the review period from October 31, 2008, to July 2013 and commitments that were in progress at the beginning of the audit period (October 2008). 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 were included in the sample, but the review was limited to verification of restoration of compliance, not the specific methods used. Before the audit, the NRC staff searched Agencywide Documents Access and Management System (ADAMS) for the regulatory commitments in the licensee's submittals and the NRC staff's safety evaluations during the last 5 years and compiled all relevant regulatory commitments.

Additionally, the NRC staff compared the collection of commitments found in ADAMS to the list created by the licensee for the same review period to check for inconsistencies.

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 (UFSARs). Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

4.

Commitments made in the Tennessee Valley Authority {TVA) submittals regarding license renewal application, since these commitments are captured in the UFSAR. Also, the NRC staff conducts post-approval inspections for BFN units in accordance with Inspection Procedure 71003, "Post-Approval Site Inspection for License Renewal."

5.

The licensee's listed regulatory commitments that refer to the items in the attachments to the National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants" (NFPA 805) license amendment request (LAR).

These commitments do not include the commitments that are listed as the regulatory commitments in the enclosure to the LAR and its supplement.

2.1.2 Audit Results of Licensee's Implementation of NRC Commitments Prior to the audit, the licensee provided lists of regulatory commitments related to licensing actions from its commitment management system MAXIMO, and the TVA's regulatory commitment procedures to support the NRC staff's audit. The licensee's lists included: all open BFN commitments, all BFN NRC commitments initiated since July 1, 2010, commitments that have been changed during the last 3 years that were, or will be, reported to NRC, and BFN commitments that have been changed during the last 3 years that were evaluated to not be reported to NRC. The lists provide the site identification (I D), the commitment ID number, initiated date, the status of the commitment, and the priority date (or due date) for the commitment. For the audit, the licensee prepared a spread sheet that included worksheets for the BFN closed commitments, BFN open commitments, Nuclear Power Group (NPG) open commitments, and NFPA 805 LAR open commitments. During the audit, the licensee included, as needed, commitment tracking load sheets, commitment completion forms, and commitment evaluation forms, and other supporting documents for the regulatory commitments to the NRC.

For closed commitments, the licensee further provided documentation for the completion of the commitments, including return to operations notices, engineering change packages, and design change notices.

The licensee's commitment management program is described in the NPG Standard Program and Process (SPP), NPG-SPP-03.3, Revision 2, "NRC Commitment Management," effective February 19, 2013. The SPP is applicable to regulatory commitments made or modified after the effective date of this procedure. Prior to the audit, the licensee also provided the NRC staff with NPG-SPP-03.3, Revisions 0, 1, and 2. In addition, the licensee provided Revisions 8 and 9 of SPP-3.3 that was used for the NRC Commitment management prior to 2008.

During the audit, the NRC staff reviewed the licensee's procedure, NPG-SPP-03.3, Revision 2.

This revision added seven requirements to the previous revision to improve commitment management according to the latest approved Corrective Action Plan. The NRC staff found that NPG-SPP-03.3, Revision 2, provides guidance to the licensee that is consistent with the intent of NEI 99-04, and ensures that BFN is appropriately implementing regulatory commitments.

Furthermore, the NRC staff found that the procedure meets the requirements laid out in the NEI 99-04 guidance.

TVA upgraded to the MAXIMO database in 2009 from the TROI system. All commitments that were in progress at the time of the transition were carried over into MAXIMO. Commitments that were already closed were not transferred. Older closed commitments can still be searched for in the TROI system. All commitments with the code "NCO" at the beginning of the ID number were initiated in TROI, while those with a nine digit number were initiated in MAXIMO.

The MAXIMO database is used throughout the NPG fleet, including their hydroelectric and fossil fuel plants in addition to their nuclear plants. The database is accessed from an internal NPG website, selecting work orders, and then nuclear commitment tracking. Both NPG wide and BFN specific commitments can be searched. Moreover, multiple search options are available to return only open, closed, BFN specific commitments, etc. In addition to the commitments ID number, each commitment has an accession number that incorporates the day TVA processes the commitment after submitting it to the NRC. While this date frequently matches the date the NRC has on record as the commitment initiation date, it does not always. Commitment load sheets are completed as soon as a commitment is written. TVA requires that a load sheet is completed before submitting commitments to the NRC. TVA corporate licensing staff and BFN licensing support staff can both add commitments to MAXIMO. Each commitment is listed with a "Commitment Status Date." This date reflects the last action completed in MAXIMO, whether the commitment was opened, closed, or edited. In 2012, TVA updated its policy on documentation, and now requires hardcopies of all commitment closure-related documents in the closure packages in addition to electronic copies. Previous to 2012, only electronic copies of the documents were required. All TVA documents are stored in the Enterprise Document Management System (EDMS). The newest commitments entered into MAXIMO contain links for their associated documents, which are also contained in hardcopy in the closure package.

Each commitment's due date is assigned to either the administrative "A" or commitment "C" category in the load sheet. Administrative due dates are internal and do not require NRC approval to be extended. Commitment due dates are docketed and, thus, require NRC approval for an extension. TVA labels commitments that are repeated over specified periods of time or are part of procedures or primitive maintenance activities as "programmatic."

The licensee's documentation includes commitment tracking load sheets, which are used to open a commitment in MAXIMO. The load sheets provide long and short descriptions of the commitment, priority date/due date, commitment category (A, C, or Programmatic), and type code that identifies regulatory commitments in response to different types of actions or communications with the NRC. The load sheet also has an EDMS reference number that links the commitment to its originating commitment. MAXIMO's commitment ID is added manually to the load sheet.

During the audit the NRC staff interviewed the TVA personnel and reviewed documentation generated by the licensee for the sample of the regulatory commitments listed in the enclosure in order to assess the implementation of each regulatory commitment, including the completion status. For the commitments selected for the audit, the NRC staff found that the licensee had adequately captured all but two of the regulatory commitments audited in their MAXIMO system.

One of these commitments was withdrawn from MAXIMO due to NRC guidance. NRC did not receive notification documenting the withdrawal, but as the removal of the commitment was completed according to NRC's recommendation, the NRC staff does not consider this a major issue. A second commitment was overlooked when a supplement letter dated May 16, 2013, updated the regulatory commitments in the original LAR dated March 27, 2013. A new commitment (Commitment No. 19) was added to the updated list, but TVA did not enter the new commitment into MAXIMO (refer to Commitment 75 in the attached table).

The NRC staff noticed that the commitment descriptions that were provided in the commitment load sheets and MAXMO did not always capture the exact wording of the regulatory commitment or a clear link to the commitment originating document. Therefore, it was not easy to compare the list provided by the licensee against the list of commitments found by the NRC staff from ADAMS.

The NRC staff reviewed the status of the implementation of the regulatory commitments that were made since the beginning of the audit period in 2008 and the commitments that were in progress in 2008. The NRC staff did not find any commitments that were completed past their priority date. It was noted however, that the MAXIMO database records the closure date of the commitment as the date the responsible TVA manager signs the closure package, not the actual date of commitment implementation. While the actual implementation date is listed in the commitment closure package, the signature date listed in MAXIMO often makes it appear that commitments are late, when they in fact are not.

The NRC staff noted that some older document submittals contained commitments in the document content that were not specifically identified under a "List of Regulatory Commitments" enclosure. While TVA did not identify these commitments in the submittal to the NRC, they were entered as regulatory commitments into the MAXIMO database, and they were correctly managed.

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 verified that the procedures that are affected by a regulatory commitment are identified in the MAXIMO database under the TVA commitment ID assigned for that commitment. Furthermore, in the procedure content, the related commitment is referenced directly after the subject matter in brackets. For a period of time TVA changed its commitment reference system by listing all referenced commitments in a separate document. This practice is currently being reversed; as procedures are updated, TVA is reverting back to the bracketed reference system.

The licensee's procedure owners are advised to refer to all the regulatory commitments associated with each procedure, prior to making any changes to the procedure. Details for how to handle procedural changes due to new regulatory commitments or commitment changes are included in TVA's procedure NPG-SPP-01.1, "Administration of Standard Programs &

Procedures (SPPs); Standard Department Procedures (SOPs); and Business Practices (BPs),"

Revision 2. The review of the sample commitments and their affected procedural changes as documented in the commitment closure package were consistent with their counterparts tracked in the MAXIMO database and as documented by the NRC. The attached "Summary of Audit Results" 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 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. The process used at BFN is contained in the NPG-SPP-03.3, which is based on and implements the recommendations of NEI 99-04. The audit reviewed 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.

2.2.1 Audit Results of the Licensee's Program for Managing NRC Commitment Changes The NRC staff reviewed the licensee's procedure NPG-SPP-03.3, Revision 2, against NEI 99-04 to ensure that guidance in this procedure is consistent with the intent of NEI 99-04, and that BFN is appropriately implementing regulatory commitment changes, as well as tracking changes to the commitments.

The NRC staff found that NPG-SPP-03.3, Revision 2, 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 filling out the "Commitment Evaluation Form" instructions for which can be found in Attachment D of the procedure. The NRC staff reviewed this form and found it consistent with the intent of the "Commitment Evaluation" form in NEI 99-04.

During the audit, the licensee provided documentation for all commitment changes that have been, or will be, reported to the NRC in addition to those that have not been, and will not be,

. reported. The NRC staff reviewed the Commitment Evaluation Form for those changes that were reported to the NRC as well as for those that did not meet the NEI 99-04 criteria for reporting to the NRC. These changes were captured in MAXIMO and provided in a commitment closure package (for the closed commitments). Discussions with BFN staff confirmed that changes to regulatory commitments are generally being handled in accordance with the guidance contained in NEI 99-04.

During the audit, the NRC staff reviewed the licensee's letter dated November 30, 2011, "Summary Report for [Title 10 of Code of Federal Regulations] 10 CFR 50.59 Evaluations, Fire Protection Report Revision, Technical Specifications Bases Changes, Technical Requirement Manual Changes, and NRC Commitment Changes," which includes a summary of the BFN regulatory commitment changes for the period of July 1, 2009, through June 10, 2011. No "NRC Commitment Changes" were reported in the previous report dated November 30, 2009.

The November 30, 2011, letter contained two changes to one regulatory commitment regarding the total required operations staffing for Appendix R safe shutdown (SSD), as stated in the TVA's letter dated November 15, 2006. The licensee stated that this regulatory commitment was revised in accordance with the NEI 99-04 guidelines. Accordingly, the licensee notified the NRC of this change in regulatory commitment changes in its November 30, 2011, letter.

Specifically, TVA, by letter dated November 15, 2006, requested an Appendix R license amendment. On page E1-7 of this request, the licensee stated that:

Operations staffing to support the Appendix R Safe Shutdown analysis and the implementation of the three unit Safe Shutdown Instructions (SSis) have also been evaluated. Additional staffing to support combined Units 1, 2, and 3 SSis includes an additional Unit Supervisor (US) Reactor Operator (RO), and two Auxiliary Unit Operators (AUOs) with a total staffing level one Shift Manager, four USs, six ROs, eight AUOs, and one Shift Technical Advisor [STA] as listed in TVA Department Procedure OPDP-1, "Conduct of Operations." The combined Units 1, 2, and 3 staffing requirements will be met prior to entering Mode 2.

Based on the NRC staff review of the November 15, 2006, request for license amendment, including the above requirements for total SSD staffing, the NRC issued Amendment Nos. 271, 300, and 259 for BFN Units 1, 2, and 3, dated April25, 2007. The NRC staff's safety evaluation that restated required staffing was referenced in the Fire Protection License Conditions for BFN Units 1, 2, and 3, Conditions (13), (14), and (17) respectively, to accommodate operation for BFN's three units.

During the audit, the NRC questioned the TVA's conclusion that only notification was required.

Based on the review of the TVA evaluation of the change, the NRC staff believed that the licensee should have requested the NRC's approval of the change.

Following the audit, the NRC project manager noticed that, on May 13, 2010, the licensee had notified the Region II Regional Administrator (RA) via a conference call that the staffing levels provided in OPDP-1 for minimum on-shift staffing did not meet the staffing levels submitted in Amendment Nos. 271, 300, and 259. By a 10 CFR 50.9 letter dated June 29, 2010, the licensee informed the RA that it did not meet the requirements of its licensing basis for BFN.

The licensee also stated that it had completed a staffing assessment and determined that the existing minimum staffing levels contained in the procedure (i.e., three USs with one US filling the STA function) were adequate for successful implementation of all SSD actions for the bounding Appendix R fire scenario. However, as discussed earlier, TVA evaluated the staffing change as a regulatory commitment change and determined that no NRC's approval was needed and reported this change to the NRC in its November 30, 2011, letter for the commitment changes. This issue is currently under review by the NRC's staff at the headquarters and Region II staff, as apparent violations.

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

The NRC staff found that the TVA instruction for managing regulatory commitments, NPG-SPP-03.3, Revision 2, is consistent with the NEI 99-04 guidelines pertaining to commitment changes. However, TVA staff may need to better understand the applicability and implementation of commitment change evaluation.

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 NRC staff relied on the action comprising the commitment 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 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 included in the audit were reviewed to determine if any had been misapplied. No commitments were found 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 commitments included in the audit, all license amendment safety evaluations, exemptions, and relief request safety evaluations that have been issued for a facility during the last 5 years were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above. Included in the "Summary of Audit Results" is a list of licensing actions reviewed during this audit period.

2.4 Audit Observations and Suggestions During the audit, the NRC staff noticed that:

(1)

The Commitment Tracking Database used by TVA does not provide a link or ADAMS accession number of the document in which the specific commitment was initially listed.

NPG-SPP-03.3, Revision 2, states, "Close these commitments by referencing the withdrawal letter in the commitment database actions taken field. For example, add a note to the actions taken field similar to the following, 'This commitment was withdrawn in TVA's letter to NRC dated mm/dd/yyyy (EDMS accession numbe(J.' The NRC staff recommends applying this principle to all commitments, not only those in the closure process. Additionally, referencing the ADAMS accession number in addition to the EDMS accession number would help to compare TVA documents to NRC documents."

(2)

TVA uses the Commitment Tracking Database for all kinds of commitments for BFN (i.e.,

regulatory commitments, internal commitments, license renewal commitments, state commitments, etc.) to streamline the process. While this practice is convenient for a general view of all commitments, it was difficult to extract the commitments solely for this regulatory commitment audit with ease. Several lists had to be provided, parts of which were redundant. It would be beneficial to initiate a system for identifying the different kinds of commitments with ease. Options could include starting the name of each commitment with a code name (e.g., "Reg. Comm.") or inserting an additional column in the database with a similar code name. The goal is to make all commitments of a certain type easily searchable for audits in the future.

(3)

Within the lists from the Commitment Tracking Database provided by TVA were repeated commitments. This is a concern for effectively closing out commitments. If the commitment is completed but only one copy of the commitment is closed, according to the database the commitment is both open and closed. This confusion and the problems it could induce should be avoided by deleting out duplicates.

(4)

The wording in the Commitment Tracking Database, while similar to the commitments recorded in ADAMS documents from TVA, is not exactly the same. It would be easier to confirm consistencies between TVA's and NRC's commitments for BFN if the wording was identical.

(5)

The NPG-SPP-03.3 document is a very detailed guide for managing NRC commitments, however it does not provide insight on dealing with commitments that should be obligations. While the guidance acknowledges the difference between commitments and obligations, it does not lay out the process for changing commitments to obligations if required.

The licensee's staff has captured the issues that were identified during the audit in its corrective action program in the following service requests (SRs) and later in problem evaluation reports (PEAs):

PER 768396 - SR 767244: Commitment Change Evaluation Form for Commitment No. 114336733 incorrectly determined the change did not need to be reported to the NRC. The evaluation concluded that NRC notification was not required. However, the change was reported to the NRC in L44 130426 003. The NRC auditors believed that the responses to the evaluation form questions were answered incorrectly that NRC notification was required. The NRC auditor concluded this was a learning opportunity for better understanding of the Commitment Change Evaluation Process.

PER 768399 -SR 767251: The second revision to 111323035 was not captured in MAXIMO.

PER 770017 - SR 767252: Commitment Change Evaluation Form does not require the change to be captured in Commitment tracking Database.

PER 770019 - SR 767255: The May 16, 2013 NFPA 805 LAR Supplement Letter contained a new regulatory commitment. This commitment has not been loaded in MAXIMO. No Completed Load Sheet could be located. The NRC auditor did not consider this an issue, because NFPA 805 LAR is still under NRC review.

PER 770254 - SR 768437: Commitment Management Process Improvement Recommendations.

o The Completion Date in MAXIMO does not always match the actual Closure Package Commitment Completion Date on the closure form. However, there was no instance where a commitment was not completed before the due date.

o TVA could be more consistent in the way Regulatory Commitments are identified in their submittals.

PER 768404: A change to Regulatory Commitment 111323035 was evaluated in accordance with NPG-SPP-03.3. The evaluation determined that BFN could revise this commitment without NRC Approval and notify the NRC in the periodic summary report.

During the BFN Commitment Audit, the NRC questioned the TVA's conclusion that only notification is required. See Section 2.2.1 for details.

3.0 CONCLUSION

The NRC staff concludes that, based on the above audit, except for the aforementioned potential finding and other minor issues, (1) the licensee has implemented, or is tracking for future implementation regulatory commitments; (2) the licensee has implemented a program to manage regulatory commitment changes that is consistent with the guidance in NEI 99-04; and (3) the regulatory commitments are generally characterized as commitments versus obligations.

Overall, the NRC staff believes that TVA has made progress in its commitment management procedures in recent years. Details of the audit are set forth in the enclosed report.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Thomas Hess, TVA Corporate Licensing Principal Contributors: Farideh E. Saba Naomi A Lisse Date: April 7, 2014

Attachment:

Summary of Audit Results

SUMMARY

OF AUDIT RESULTS IMPLEMENTATION AND MANAGEMENT OF COMMITMENTS*

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment I Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 1

The first performance of the periodic NC0080018002 ML083650227 12/19/2008 7/16/2010 7/19/2010/

Closed assessment of the Control Room By a letter to Envelope (CRE) Habitability, the NRC.

Technical Specification 5.5.13.c.(ii),

shall be within 9 months following the initial implementation of the TS Change. The next performance of the periodic assessment will be in a period specified by the specified by the Control Room Envelope Habitability Program. That is 3 years from the last successful performance of the Technical Specification 5.5.13.c.(ii) tracer gas test.

2 The Automatic Depressurization 113108916 (U3, ML101250173 4/30/2010 4/27/2012 05/17/2012 Closed System (ADS) will be modified to DCN 69959) provide a single failure proof (due date automatic initiation capability of 4 4/27/12 ADS valves, regardless of which completed on 250VDC batter fails. This 5/17/12) modification is expected to be made to BFN, Unit 3, during the Unit 3 outage in the spring of 2012 and to BFN, Unit 2, during the Unit 2 outage in the spring of 2013.

1 The commitment was to complete modification during the Unit 3 Outage in the spring of 2012. The original due date did not account for changes in outage schedule. This modification was completed prior to Unit 3 starting up following the spring 2012 Outage.

Attachment I

I Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 3

TVA will submit a license amendment 113359259 ML12017A186 1/13/2012 3/30/2013 4/17/2013 Closed request for Browns Ferry Nuclear Plant, Units 1, 2, and 3, to adopt NFPA Standard 805 by no later than March 29, 2013.

4 With respect to clarifying the No Tracking ID ML101590108 5/28/2010 07/30/2010 Withdrawn by Closed regulatory commitments regarding letter dated the use of the extended CT for 11/12/2010.

maintenance activities and/or the compensatory measures that will be used forTS Action entries that are not part of a planned maintenance activity, TVA will revise the proposed Technical Specifications and Bases and submit them to the NRC by July 30, 2010 to include the previous commitments in the proposed change as stated in Enclosure 1.

5 On or before November 30, 201 0, the 111509109 ML102790047 10/1/2010 10/31/2011 10/3/2012 Closed Tennessee Valley Authority will supplement our Cyber Security Plans to clarify the scope of systems described in Section 2.1, "Scope and Purpose." Section 2.1, will be amended to clarify the balance of plant SSCs that will be included in the scope of the cyber security program.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 6

TV A has implemented an Appendix R 112064136 ML103070133 10/29/2010 3/4/2012 12/5/2011 Closed 95002 Task Force. The Appendix R 95002 Task Force is a group sponsored by TV A Nuclear Power Group senior management that is tasked with meeting the following objectives: (see document for objective. They're listed as separate commitments) 7 General Operating Instruction, 0-111689505 ML103360040 11/29/2010 12/13/2010 12/20/2010 Closed GOI-300-1, "Operator Round Logs,"

will be revised to include: ( 1) requirements for Operations personnel to identify and correct hazards within the ISFSI Pad Exclusion Zone, and (2) Operations escort responsibilities within the ISFSI Pad Escort Zone.

-~- - - - -

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment 10 Accession No.

Date Due Date Date and Status No.

No Method of Closure 8

A. Browns Ferry Nuclear Plant (BFN) 112906021 ML11152A167 5/27/2011 1/10/2012 3/6/2012" Closed "Engineering Procedure for TOGs Temporary Initial Acceptance Testing" will direct Diesel a load test of the temporary diesel Generator generators (TOGs) initially after Surveillance acceptance from the TOGs rental Procedure 0-vendor and once per 18 months SR-3.8.1.1 (while the TOGs are in TVA's (TOG custody) which loads the pair of Implementation)

TOGs to 3.24 MWe using a resistive was revised load bank. The same procedure will under Work direct routine preventative Order No.

maintenance and a monthly unloaded 112888110.

test run, while the TOGs are onsite, but only during periods when the TOGs are not credited as available during the extended allowed outage time (AOT). If the TOGs are needed again after being out of TVA control onsite, TVA will re-perform the acceptance testing prior to entering the next planned emergency diesel generator (EDG) inoperability that exceeds 7 days.

2 This commitment was completed on Jaunty 9, 2012. However, the final signature was dated March 6, 2012.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment 1

Comm Commitment ID Accession No.

Date Due Date Date and Status I

No.

No Method of Closure I

9 B. The TOGs will be protected, as a 112906036 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed I

defense-in-depth, during the Procedure was extended AOT, and will be routinely revised under monitored when they are not required Work Order No.

to be available for the extended EDG 112888110 AOT.

10 C. Required actions during an AOT 112906053 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed greater than 7 days will be to verify Procedure was the TOGs fuel tanks are at least 90 revised under percent full and to keep one diesel Work Order No.

Fuel Oil Storage Tank at least 60 112888110 percent full.

11 D. Licensed Operators and Assistant 112906068 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed I

Unit Operators will be appropriately Procedure was I

trained on the purpose and use of the revised under TOGs and the revised Safe Work Order No.

I Shutdown Instructions (SSis). A 112888110 briefing/discussion of the revised TS 3.8.1 and putting TOGs in service will be completed prior to a planned EDG inoperability that exceeds 7 days. Operating crews will be briefed on the EDG work plan and procedural actions regarding loss-of-offsite power and s_tation blackout (SB_O).

- -L_

- * * - - - -L_

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 12 E. Operators will monitor weather 112906104 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed forecasts each shift. Weather Procedure was conditions will be evaluated prior to revised under intentionally entering the extended Work Order No.

EDG outage and will not be entered if 112888110 official weather forecasts are predicting severe conditions (tornado or thunderstorm warnings). If severe weather or grid instability is expected after an EDG outage begins, station managers will assess the conditions and determine the best course for returning the EDG to an operable status.

~-

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 13 F. The Transmission Operator 112906152 M L11152A 167 5/27/2011 1/10/2012 12/12/2011 Closed system dispatcher will be contacted Procedure was once per day and BFN will inform the revised under dispatcher of the EDG status along Work Order with BFN offsite power needs. Prior No. 112888110 to entering a planned EDG inoperability that exceeds 7 days, BFN Operating Crew will hold discussions with the system load dispatcher to ensure no significant grid perturbations are expected during the planned EDG inoperability that exceeds 7 days, and request that the system load dispatcher inform BFN if offsite power conditions change during a planned EDG inoperability that exceeds 7 days such that significant grid perturbations do occur or become expected.

14 G. No discretionary switchyard 112906172 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed maintenance will be allowed during Procedure was the extended EDG maintenance revised under period.

Work Order No.

112888110 Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 15 H. High Pressure Coolant Injection 112906184 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed pump, Reactor Core Isolation Cooling Procedure was pump, and the Residual Heat revised under Removal pump associated with the Work Order No.

operable EDG will not be removed 112888110 from service for elective maintenance activities during the planned extended EDG AOT.

16 I. TS Basis 3.8.1 B.2 is being revised 112906201 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed to clarify the frequency requirements TS Basis for the verification of TOGs 3.8.1.B.2 is availability. The revised wording is changed.3 below:

"In order to extend the Required Action B.5 Completion Time for an inoperable EOG from 7 days to 14 days inoperable, it is necessary to verify the availability of the TOGs I

within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> on entry into TS 3.8.1 L90 and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter."

3 It was not clear how changes to TS Bases were marked for the commitments Reg Commitment Summary TVA Document Document Scheduled Completion Commitment I Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of I

Closure I

17 J. Compensatory actions for fire 112906273 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed I

protection impairments associated Procedure was I

with the Yellow violation will remain in revised under I

effect. In addition, TVA will Work Order No.

implement additional actions that will 112888110 I

mitigate fire risk during the extended I

AOT for each EOG, as follows:

1. TVA will perform a qualitative I

analysis on electrical circuits/cable I

routing for each out-of-service (OOS)

EOG for the 14-day AOT. This analysis will identify the fire areas where there is a lack of adequate cable separation associated with use of the TOGs. Hourly fire watches will be in effect for these areas. After the 7th day of the extended 14-day AOT, a continuous fire watch will be provided for the fire areas which lack cable separation, as identified in the Qualitative Analysis.

2. TVA will revise the SSis to incorporate guidance for use of the TOGs as an alternate alternating current (AC) power source for each OOS EOG. Additional or revised operator manual actions associated with the use of the TOGs in the SSis Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure will be minimized and validated. The TOGs as a replacement for an OOS EOG. Operators will be trained on the revised SSis.

3. After the 7th day of the extended 14-day AOT, an operator will be stationed at the TOGs to start the TOGs when directed, and to ensure reliable operation and equal load sharing of the TOGs.

4. TVA will impose additional restrictions on hot work in the affected fire zones/areas, and on elective work on Appendix R components.

5. Fire Operations personnel will perform walk downs to verify required controls of transient combustibles in affected fire zones/areas that could impact the operable EOGs, the TOGs' availability, offsite power availability, or the ability to use the Bus Tie Board prior to entering and during each shift for the duration of the extended AOT.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment 10 Accession No.

Date Due Date Date and Status I

No.

No Method of Closure I

18 K. Revise appropriate procedures 112909205 ML11152A167 5/27/2011 1/10/2012 12/12/2011 Closed such that the initial emergency Procedure was I

equipment cooling water pump is revised under I

supplied by one of the remaining Work Order No.

credited EDGs. The TOGs will be 112888110 available in time to support the remaining functions which rely on AC power during a SBO.

19 L. Procedure 0-SR-3.8.1.1 (OPS 112909245 1/10/2012 12/12/2011 1/10/2012 12/12/2011 Closed TOG Implementation) will include Procedure was Manhole "E" sump pump monitoring.

revised under Work Order No.

112888110 Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 20 This is a cover letter for commitment ML11343A051 11/30/2011 N/A

20.

20 The above revised commitment was 111323035 ML11343A052 11/30/2011 12/31/2010 5/5/2011 Closed 4

re-evaluated and revised on October 25, 2010, using administrative controls that incorporate Nuclear Energy Institute 99-04, "Guideline For Managing NRC Commitments." The revised commitment, in italic, reads as follows:

"...Total staffing level is one Shift Manager (SM), three Unit Supervisors (USs), six ROs, and eight AUOs. One of the US may be the ST A. The incident Commander position shall be filled by an additional qualified person... "

21 TVA will submit a detailed list of 113359371 ML12017A186 1/13/2012 2/17/2012 2/17/2012 Closed additional planned fire protection modifications for Browns Ferry Nuclear Plant, Units 1, 2, and 3, and associated implementation schedules by February 17, 2012.

22 The Tennessee Valley Authority will 113418296 ML121850007 6/29/2012 7/30/2012 7/31/2012 Closed submit the revised Loss of Coolant Summary report Accident (LOCA) Analysis for Browns was submitted Ferry Nuclear Plant, Units 2 and 3, to to the NRC. 5 the NRC for review and approval by July 30, 2012.

4 This is discussed under changed and misplaced commitments.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 23

1. TVA will provide the information in 113495108 ML12136A131 5/11/2012 6/11/2012 3/1/2013 Closed Requested Information Item 2 for the Communications Assessment (page 2 of the Communications section of of the letter) and Requested Information Items 3, 4 and 5 of the Staffing Assessment (page 3 of the Staffing section of ) ~June 11, 2012.

24

2. TVA will provide the information in 113495091 ML12136A131 5/11/2012 10/31/2012 11/1/2012 Closed Requested Information Items 1 and 3 for the Communication Assessment (page 2 of the Communications section of Enclosure 5 of the letter) by October 31, 2012.

25

3. TVA will provide the information for 113495035 ML12136A131 5/11/2012 4/30/2013 5/5/2013 Closed Phase 1 (addressing the functions except those related to NTTF Recommendation 4.2) for Requested Information Items 1, 2, and 6 of the Staffing Assessment (pages 2 and 3 of the Staffing section of Enclosure 5 of the letter) by April 30, 2013.

5 This is also a change to the due date from June 30, 2012 to July 30, 2012. The licensee notified the NRC by a letter dated June 29, 2012, of this change.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 26

4. TVA will provide the information for 113495007 ML12136A131 5/11/2012 11/2/2014 Open Phase 2 (addressing all functions including consideration of the results of NTTF Recommendation 4.2) for Requested Information Items 1, 2, and 6 of the Staffing Assessment (pages 2 and 3 of the Staffing section of Enclosure 5 to the letter) by dates that are four months before the earliest second refueling outage at each WVA operating site (Browns Ferry, Sequoyah, and Watts Bar) after the February 28, 2013, submittal of the Implementation Plans as required by NRC Order EA-12-049).

[The projected dates, as based on the current forecast dates for those refueling outages, are provided in the tables in Enclosure 1 of this letter.]

27

5. TVA will provide an updated status 113494915 ML12136A131 5/11/2012 6n/2013 6/10/2013 Closed of the completion schedule for the Phase 2 Staffing Assessment for Watts Bar specifically identifying any potential impact its completion resulting from the schedule of completion of Watts Bar Unit 2, by June 7, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 28

1. TVA will develop documented 113594655 ML12164A678 6/11/2012 3/29/2013 3/27/2013 Closed guidance for deploying the portable generators procured for charging satellite phone batteries during and after a Beyond Design Basis External Event by March 29, 2013.

29

2. TVA will complete an evaluation of 113594558 ML12164A678 6/11/2012 1/31/2013 1/30/2013 Closed the need for additional transportation resources and access methods by January 31, 2013.

30

3. TVA will complete familiarization 113594602 ML12164A678 6/11/2012 12/31/2012 12/20/2012 Closed and emphasis of the revised ERO reporting expectations in case of large scale events when communications systems are challenged or are not working with ERO personnel by December 31, 2012.

31

1. A new radio system will be ready 114096057 ML12311A297 10/31/2012 10/15/2014 Open for service at Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants by October 15, 2014.

32

2. TVA will purchase mobile radios 114096067 ML12311A297 10/31/2012 10/15/2014 Open and supply a portable satellite phone and spare battery for use in the NPG

~-

Fi_EP\\/_ans _IJy OctobE~r 15, 201 ~-

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 33

3. TVA will evaluate moving the fixed 114096266 ML12311A297 10/31/2012 10/15/2014 Open Satellite phone antenna at each site to the roof of the Control Building so that the fixed satellite phone will remain protected from environmental and radiological conditions and available for use in the Emergency Response Facilities (ERFs) by October 15, 2014.

34

4. TVA will purchase a mobile 114096274 ML12311A297 10/31/2012 10/15/2014 Open Meteorological Tower for each site by October 15, 2014.

35

5. TVA will establish programmatic 114096292 ML12311A297 10/31/2012 10/15/2013 Open controls for EP-related communications systems/equipment to ensure availability and reliability including the requirements in Section 4.8 of NEI12-01 by October 15, 2014.

36

6. TVA will evaluate the need for 114096303 ML12311A297 10/31/2012 10/15/2014 Open programmatic controls for the Government Emergency Telephone System (GETS)/Wireless Priority Service (WPS) programs by October 15, 2014.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 37

7. TVA will evaluate the need for 114096309 ML12311A297 10/31/2012 10/15/2014 Open SBO/Extended Loss of AC Power actions/tasks associated with shedding/restoring loads (sequencing) once AC power is restored or available by October 15, 2014.

38

8. TVA will evaluate the need for 114096316 ML12311A297 10/31/2012 10/15/2014 Open Extended Loss of AC Power actions/tasks using a systematic approach to training (SAT) process and include results in the Operations Training, applicable Technical Training, Security, and ERO Training Programs by October 15, 2014.

39 Technical Instruction 0-TI-565, One-114457892 ML13067A398 2/28/2013 10/1/2013 Open Time Inspection Procedure to include acceptance criteria for inspection of elastomer components and specific guidance on determining the number of inspections to be performed for each aging effect within an inspection group by 1 0/1/13.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment !

Comm Commitment ID Accession No.

Date Due Date Date and Status I

No.

No Method of Closure I

40 When using AREVA Topical Report 114210392 ML13070A307 2/28/2013 4/30/2015 Open BAW-1 0247PA, Realistic Thermal Mechanical Fuel Rod Methodology for Boiling Water Reactors, Revision 0, February 2008, to determine core operating limits, the fuel cladding peak oxide thickness calculated by RODEX4 will be limited to less than the proprietary value defined in section 3.2.7 of AREVA report ANP-3159P revision 0, dated October I

2012. Completion date: Upon implementation of the Unit 1, 2, and 3 I

license amendments authorizing the incorporation of AREVA Topical Report BAW-10247PA into Technical Specification 5.6.5.b.

41

1. TVA will submit a License 114569391 ML13141A291 5/16/2013 Open Amendment Request proposing Technical Specifications requirements for the new emergency high pressure makeup pump system on a schedule to support the modification implementation date provided in Section 5.5 of the enclosure to this letter.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 42

2. TVA will revise the program that 114569398 ML13141A291 5/16/2013 Open monitors BFN Residual Heat Removal (RHR) heat exchanger performance for consistency with the assumptions of the NFPA 805 Net Positive Suction Head (NPSH),

Containment Parameters, and AREVA Fuel peak centerline temperature (PCT) Analysis calculation related to the RHR heat exchanger k-factor within 6 months following NRC approval of this amendment request.

43

3. TVA will maintain the existing 114563404 ML13141A291 5/16/2013 5/31/2013 7/17/2013° Closed hourly roving fire watches for all Verification will existing BFN fire areas (FAs): until be done by the modifications described in inspection.

AttachmentS, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

The hourly roving fire watches for all existing BFN FAs is currently implemented.

6 This is the paperwork closure date. The commitment was completed on 5/30/13 with the issuance of the procedure revision (see closure package R20130717033). This footnote is applicable to all the commitments with the same scheduled due date and completion due date associated with the same document accession number (ML13141A291).

I I

I Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 44

4. TVA will implement stricter control 114569179 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed of transient combustibles for the Verification will I

following BFN FAs: FA 01-03, FA 01-be done by I

04, FA 02-02, FA 02-03, FA 02-04, inspection.

FA 03-01, FA 03-02, FA 03-03, FA I

04, FA 08, FA 09, FA 16 (except for Main Control Room), FA 20, FA 21, FA 22, FA 23, FA 24, FA 25-01, and FA 26 until the modifications I

described for the listed FAs in AttachmentS, Table S-2, "Plant I

Modifications Committed," of the enclosure to this letter are installed.

These controls will consist of:

I

a. Requiring permits to allow transient combustibles into these higher risk areas;

b. Tracking these permits to control quantities of transient combustibles allowed into these fire areas; and

c. Performing once-per-shift walkdowns to ensure that transient combustible controls are satisfied (e.g., waste, debris, scraps, rags, or other combustibles resulting from work activities are removed from the subject fire areas, and that no transient combustibles are placed in the 20-foot exclusion zone(s) within the listed FAs).

TVA will implement these controls by May 31,2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 45

5. TVA will implement controls 114569185 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed limiting hot work activities (e.g.,

Verification will welding, cutting, and grinding) in FA be done by 01-03, FA 01-04, FA 02-02, FA 02-inspection.

03, FA 02-04, FA 03-01, FA 03-02, FA 03-03, FA 04, FA 08, FA 09, FA 16, FA 20, FA 21, FA 22, FA 23, FA 24, FA 25-01, FA 26, and FA SWITCH until the modifications described for the listed FAs in AttachmentS, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed. If hot work activities are necessary, the existing hot work controls specified in NPG-SPP-18.4.8, Control of Ignition Sources, shall be augmented to require that the Fire Brigade or Senior Reactor Operator perform a pre-job briefing in accordance with NPG-SPP-18.2.2, Human Performance Tools, and perform a walkdown for job area familiarization prior to performing the hot work activity. This walkdown shall include, ensuring travel path is clear of I

obstructions, identifying the location of fire hoses and fire extinguishers, and verifying fire suppression I

systems (manual and automatic) are properly aligned. TVA will implement these controls by May 31, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 46

6. TVA will implement controls to 114569214 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed credit temporary diesel generators as Verification will an additional power source for a be done by shutdown board, except during those inspection.

periods when the temporary diesel generators are being used to support alternate decay heat removal until the modifications described in AttachmentS, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

47

7. TVA will implement controls to 114569217 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed protect RHR Pump 1 A and its Verification will associated support systems be done by whenever hot work activities are inspection.

performed in FA 01-04, FA 04, and FA 09 until the modifications for the listed FAs described in AttachmentS, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed. TVA will implement these controls by May 31, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 48

8. TVA will implement controls to 114569224 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed protect the Unit 1 RHR Train A and Verification will its associated support systems be done by whenever hot work activities are inspection.

performed in FA 08 until the modifications associated with FA 08 described in AttachmentS, TableS-2, "Plant Modifications Committed,"

of the enclosure to this letter are installed. TVA will implement these controls by May 31, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 49

9. TVA will implement controls to 114569344 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed protect the following equipment Verification will whenever hot work is being be done by performed in FA 02-02 until the inspection.

modifications for FA 02-02 described in AttachmentS, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed:

a. Fire protection systems (detection and suppression) for this FA; b. north emergency equipment cooling water (EECW) header; c. 4kV Shutdown Board B, 3EA, 3EB; d. 250V DC Battery Charger 1; e. 480V reactor motor operated valve (RMOV) Board 1 A, 2A, 2D;. 480V Shutdown Boards 1A and 2A; g. 2C RHR Pump; h.

480V Shutdown Board 2A Transformer TS2A; and Shutdown Board 250V DC Battery Charger SB-B. TVA will implement these controls by May 31, 2013.

J Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 50 1 0. TVA will implement controls to 114569351 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed protect the following equipment Verification will whenever hot work is being be done by performed in FA 02-03 until the inspection.

modifications for FA 02-03 described in Attachment S, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed:

a. Fire protection systems (detection and suppression) for this FA;

b. North EECW Header;

c. Residual Heat Removal Service Water (RHRSW) Pump D1;

d. 4kV Shutdown Board D, 3EA, 3EB;

e. 250V DC Battery Charger 1;

f. 480V RMOV Board 1 A, 2B, and 3A;

g. 480V Shutdown Boards 1A and 2B;

h. 2D RHR Pump & RHR Crosstie Unit 3 to Unit 2; and

i. 480V Shutdown Board 2B Transformer TS2B. TVA will implement these controls by May 31, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 51

11. TVA will implement controls to 114569356 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed protect the following equipment Verification will I

whenever hot work is being be done by performed in FA 02-04 until the inspection.

I modifications for FA 02-04 described in Attachment S, Table S-2, "Plant I

Modifications Committed," of the enclosure to this letter are installed:

I

a. Fire protection systems (detection and suppression) for this FA;

b. North EECW Header;

c. B1 and D1 RHRSW Pump;

d. 4kV Shutdown Board D, 3EA, 3EB, and 3ED;

e. Shutdown Board 250V DC Battery Charger SB-D;

f. 480V RMOV Board 1 A and 3B;

g. 2D RHR Pump; and

h. 480V Shutdown Board 2B Transformer TS2B.

TV A will implement these controls by May 31, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status I

No.

No Method of Closure I

52

12. TVA will implement controls to 114569364 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed protect RHRSW Pump 28 and its Verification will I

associated support systems be done by whenever hot work activities are inspection.

I performed in FA 03-03 until the modifications for FA 03-03 described I

in Attachment S, Table S-2, "Plant Modifications Committed," of the I

enclosure to this letter are installed.

TVA will implement these controls by May 31, 2013.

I 53

13. TVA will institute 30-minute 114569369 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed roving fire watches in FA 16 for non-Completed by continuously manned areas until the fire protection modifications for FA 16 described in impairment Attachment S, Table S-2, "Plant permit No.

Modifications Committed," of the 13-4035.

enclosure to this letter are installed.

TV A will implement these controls by May 31, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 54

14. TVA will designate the FA 04, FA 114569374 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed 08, FA 09, FA 16 (Cable Spreading Verification will Room only}, FA 22, FA 23, FA 24, be done by and FA 25-01 as transient inspection.

combustible-free areas and establish the same controls as the current 20-foot exclusion zones, except that tags required by plant procedures may be present in these FAs, until the modifications for the listed FAs described in AttachmentS, Table S-2, "Plant Modifications Committed,"

of the enclosure to this letter are installed. TV A will implement these controls by May 31, 2013.

55

15. TVA will implement controls to 114569379 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed limit the unavailability of an entire Verification will EECW header (north or south) until be done by the modifications for FA SWITCH inspection.

described in AttachmentS, Table S-2, "Plant Modifications Committed,"

of the enclosure to this letter are installed. TV A will implement these controls by May 31, 2013. - * - -- -

L_

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment I Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 56

16. TVA will increase the testing 114569381 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed frequency of automatic fire doors in Verification will FA 22, FA 23, and FA 24 to once-be done by per-6 months until the modifications inspection.

described for the listed FAs in AttachmentS, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TV A will implement these controls by May 31, 2013.

57

17. TVA will implement controls to 114569383 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed protect the following equipment Verification will whenever hot work is being be done by I

performed in FA 20 until the inspection.

modifications for FA 20 described in I

AttachmentS, Table S-2, "Plant Modifications Committed," of I

the enclosure to this letter are installed:

a. Fire protection systems (detection and suppression) for this FA;

b. North EECW Header;

c. 4kV Shutdown Board 3EA and 3EB;

d. 480V Common Board 1 Transformer TC1 A; and

e. 250V DC Battery Charger 1.

TVA will implement these controls by May 31,2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 58

18. TVA will implement controls to 114569386 ML13141A291 5/16/2013 5/31/2013 7/17/2013 Closed ensure that Heating, Ventilation and Verification will Air Conditioning (HVAC) is available be done by to the BFN Unit 3 Main Control Room inspection.

I whenever Transformer TS3A is unavailable or the EECW South Header is unavailable until the modifications for FA 20 described in AttachmentS, Table S-2, "Plant Modifications Committed," of the enclosure to this letter are installed.

TV A will implement these controls by May 31, 2013.

59

1. TVA will complete a 114618583 M L 13123A 163 4/30/2013 12/31/2014 Open comprehensive evaluation of commercial grade dedicated items installed between September 1995 and November 2011 for the operating fleet, and correct any identified deficiencies by December 31, 2014.

60

2. TVA will provide the NRC with 114489096 ML13123A163 4/30/2013 12/31/2017 Open periodic written updates regarding progress of the project by the last day of July, October, January, and April of each year until the project is completed, beginning with the first written report to be filed by July 31, 2013.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 61

1. TVA will complete flooding 114251117 ML12335A340 11/27/2012 4/20/2013 4/20/2013 Closed walkdowns of the main steam tunnel Submitted to flood walls at Browns Ferry Nuclear the NRC Plant, Unit 2, during the next refueling outage scheduled for the spring of 2013.

62

2. TVA will complete flooding 114251083 ML12335A340 11/27/2012 4/4/2014 Open Open walkdowns of the main steam tunnel flood walls at Browns Ferry Nuclear Plant, Unit 3, during the next refueling outage scheduled for the s_2ring of 2014.

63

1. TVA will complete seismic 114251200 ML13002A487 11/27/2012 4/20/2013 5/3/2013 Closed walkdowns of the areas that were (spring Completed unable to be inspected due to refueling during refueling inaccessibility at Browns Ferry outage) outage.

Nuclear Plant, Unit 2, during the next refueling outage scheduled for the s_2ring of 2013.

64

2. TVA will complete seismic 114251010 ML13002A487 11/27/2012 4/4/2014 Open walkdowns of the areas that were unable to be inspected due to inaccessibility at Browns Ferry Nuclear Plant, Unit 3, during the next refueling outage scheduled for the spring of 2014.

65

3. TVA will replace transformers 114252658 ML13002A487 11/27/2012 9/30/2014 Open BFN-0-0XF-219-TDA and BFN OXF-219-TDB by September 30, 2014.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 66 Maintain the Task Force through 112976925 ML103070133 10/29/2010 12/29/2015 Open completion of all root cause analysis corrective 67 Return and maintain the Fire 112976934 ML103070133 10/29/2010 12/29/2015 Open Protection System to excellent materiel and system 68 Minimize fire impairments.

112976944 ML103070133 10/29/2010 12/29/2015 Open 69 Continue to reduce risk and improve 112976954 ML103070133 10/29/2010 12/14/2014 Open safety margin on the Fire Protection System.

70 Close 95002 self-assessment 112976971 ML103070133 10/29/2010 12/29/2015 Open corrective actions and perform independent review 71 Complete the root cause corrective 112976847 ML103070133 10/29/2010 12/29/2015 Open actions as scheduled.

72 Verify the accuracy and adequacy of 112976869 ML103070133 10/29/2010 12/29/2015 Open completed 95002 actions items.

- Utilize a 95002 Problem Evaluation Report action verification form

-Utilize a closure review board

- Perform quarterly Quality Assurance assessments of corrective actions Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 73 Implement semi-annual effectiveness 112976892 ML103070133 10/29/2010 12/29/2015 Open review challenge boards by TV A Nuclear management. Challenge board members may include Executive Sponsor; Vice President, Nuclear Licensing; Site Vice President; 95002 Project Manager; Quality Assurance Manager; and others as required.

74 Routinely update NRC Region II 112976911 ML103070133 10/29/2010 12/29/2015 Open management on progress and status of meeting the Task Force objectives 75

19. TVA will inform the NRC 30 days TVA missed to ML13141A291 5/16/2013 No prior to discontinuing each of the add this Specific interim compensatory measures commitment to date identified in Commitments 3 through MAXIMO for 18, above.

NFPA 805.

76 Install fuses in ammeter circuit for 113380100 ML13141A291 5/16/2013 9/27/2013 6/26/2013 Closed Battery Board 2.

77 Install fuses in ammeter circuit for 113380116 ML13141A291 5/16/2013 9/16/2012 7/5/2012/

Closed Battery Board 3.

Modifications were completed on 06/23/12 78 Install fuses in ammeter circuit for 113380128 ML13141A291 5/16/2013 6/22/2012 7/19/2012 Closed Battery Board 4.

Modifications were completed.

Verification will be done by inspection.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 79 Install fuses in ammeter circuit for 113380138 ML13141A291 5/16/2013 4/6/2012 3/12/2012 Closed Battery Board 6.

Modifications were completed.

Verification will be done by ins_Q_ection.

80 Install controls in the Main Control 113380143 ML13141A291 05/16/2013 05/15/2012 05/18/2012 no Closed I

Room to isolate 4kV from Unit 3 (status update).

(status (estimated late 5 Shutdown Board 3EC from fire Tom will email update from date)

(commitment damage in 4kV Shutdown Refueling original February was due during I

outage Board 3EA.

commitment commitment spring 2012 list.

list) outage)

I 81 Isolate and abandon local control 113380156 ML13141A291 5/16/2013 1/11/2013 8/3/2012 Closed station for Residual heat Removal Verification will I

Service Water (RHRSW) Pump A3 be done by inspection.

82 Isolate and abandon local control 113380168 ML13141A291 5/16/2013 10/12/2012 7/19/2012 Closed station for RHRSW Pump 81.

Verification will be done by inspection.

83 Isolate and abandon local control 113380183 ML13141A291 5/16/2013 12/14/2012 10/17/2012 Closed station for RHRSW Pump B2.

84 Isolate and abandon local control 113380197 ML13141A291 5/16/2013 12/14/2012 10/17/2012 Closed station for RHRSW Pump B3.

Verification will be done by inspection.

85 Isolate and abandon local control 113380246 ML13141A291 5/16/2013 1/4/2013 9/3/2012 Closed station for RHRSW Pump C1.

Verification will be done by inspection.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment 1

Comm Commitment ID Accession No.

Date Due Date Date and Status I

No.

No Method of Closure J

86 Isolate and abandon local control 113380259 ML13141A291 5/16/2013 3/1/2013 8/30/2012 Closed I

station for RHRSW Pump C2.

Verification by I

inspection 87 Isolate and abandon local control 113380276 ML13141A291 5/16/2013 3/1/2013 8/29/2012 Closed I

station for RHRSW Pump C3.

Verification by inspection 88 Isolate and abandon local control 113380286 ML13141A291 5/16/2013 2/22/2013 2/12/2013 Closed I

station for RHRSW Pump D1.

Verification by inspection I

89 Isolate and abandon local control 113380299 ML13141A291 5/16/2013 2/15/2013 11/16/2012 Closed station for RHRSW Pump D2.

Verification by I

inspection 90 Isolate and abandon local control 113380316 ML13141A291 5/16/2013 12/14/2012 9/21/2012 Closed I

station for RHRSW Pump D3.

Verification by inspection I

91 Install relays to isolate 4kV Shutdown 113380395 ML13141A291 5/16/2013 12/1/2014 Open Board A Normal Feeder Breaker I

1614 control circuit from fire damage in 4kV Shutdown Board D.

92 Install relays to isolate 4 kV 113380702 ML13141A291 5/16/2013 12/1/2014 Open I

Shutdown Board A Alternate Feeder Breaker 1716 control circuit from fire I

damage in 4 kV Shutdown board C.

93 Install relays to isolate 4kV shutdown 113380795 ML13141A291 5/16/2013 12/1/2014 Open I

Board A Crosstie Breaker 1824 control circuit from fire damage in I

4kV Shutdown Board 3EA.

94 Install relays to isolate 4kV Shutdown 113380952 ML13141A291 5/16/2013 6/1/2013 4/17/2013 Closed I

Board D Normal Feeder Breaker Verification will 1724 control circuit from fire damage be done by in 4kV Shutdown Board C.

inspection.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 95 Install relays to isolate 4kV Shutdown 113380956 ML13141A291 5/16/2013 6/1/2013 4/17/2013 Closed Board A Crosstie Breaker 1826 Verification by control circuit from fire damage in inspection 4kV Shutdown board 3ED.

96 Separate normal power cables for 113380966 ML13141A291 5/16/2013 6/1/2014 Open 480 RMOV Board 3B from FA 13.

97 Install incipient fire detection in the 113380973 ML13141A291 5/16/2013 12/1/2014 Open Unit 1 Auxiliary Instrument Room.

98 Install incipient fire detection in the 113380987 ML13141A291 5/16/2013 6/1/2013 5/3/2013 Closed Unit 2 Auxiliary Instrument Room.

Verification by inspection 99 Install incipient fire detection in the 113380993 ML13141A291 5/16/2013 6/1/2014 Open Unit 3 Auxiliary Instrument Room.

100 Separate normal cables required for 113381009 ML13141A291 5/16/2013 12/1/2014 Open Unit 1 RCIC from FA 17.

101 Enhance the Cooling-Water System NC0040006091 08/09/2005 10/2/2013 07/06/12 Closed program to preform confirmatory License inspections of the RHRSW pump pit renewal supply piping, sluice gate valves and commitment seismic restraints in the RHRSW pump pit. Once prior to the period of extended o_l)_eration.

102 05/1 0/04 - The accessible non-NC0040006001 ML040060359 12/31/2003 12/20/2013 7/27/2012 Closed environmental qualification cables License and connections program will be renewal implemented prior to the period of commitment.

extended operation.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 103 BFN will complete evaluations of NC0080027008 ML081970084 7/11/2008 9/21/2009 10/19/2009 Closed GL 2008-01 subject systems using results of the detailed walkdowns of inaccessible piping sections and submit supplemental responses to NRC documenting completion of the walkdowns and any impact upon the GL 2008-01 response as a result of completed evaluation with 90 days following the U2 15 Refueling Outage.

104 BFN will complete the detailed NC0080027006 ML0819970084 7/11/2008 4/26/2010 4/6/2010 Closed walkdowns of BFN Unit 3 inaccessible piping sections of GL 2008-01 subject systems prior to startup from the U314 Refueling Outage.

105 BFN will complete evaluations of NC0080027009 ML0819970084 7/11/2008 7/25/2010 7/19/2010 Closed GL 2008-01 subject systems using results of the detailed walkdowns of inaccessible piping sections and submit supplemental responses to NRC documenting completion of the walkdowns and any impact upon the GL 2008-01 response as a result of completed evaluation within 90 days following startup from the U3 14 Refueling Outage.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 106 TVA Will Perform a self-assessment NC0090008001 ML083151215 2/11/2008 9/1/2009 12/20/2010 Closed on access authorization and (document has adherence to behavior observation due date as program by September 1, 2009.

fourth quarter of 200*)

107 TVA will be in full compliance with 1 0 10292967 ML093160117 11/6/2009 12/20/2012 12/6/2012 Closed CFR 73.55(i)(4)(i)(A)- (D), 10 CFR 73.55(e)(7)(i)(C) and 10 CFR 73.55(i)(3)(vii) for Browns Ferry Nuclear Plant by December 20, 2012.

108 Tech Spec Change TS-473, AREVA 112910279 ML101160153 4/16/2010 4/18/2011 3/28/2013 Closed Fuel Transition. The following Completed by revisions will be proposed for BFN submitting a Unit 2 and 3 in future Tech Spec license Change Request(s):

amendment

a. Revisions to TS 3.3.1.1, Reactor request.

Protection Systems Instrumentation, for the Oscillation Power Range Monitor Upscale Function, (i.e.,

Function 2.f, to indicate that OPRM period based detection algorithm setpoint limits are included in COLA.

b. Corresponding revisions are to TS 5.6.5.a to include the OPRM setpoint as a COLA item.

c. Revisions toTS 5.6.5.b to include the AREVA stability related Topical Reports which describe the analytical methods used for determining the OPRM period based detection algorithm setpoint limits.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 109 Implement changes to Unit 1 Periodic 113489673 ML12123A707 4/30/2012 10/10/2012 7/20/2012 Closed Inspection Program for License Renewal (1-TI-521).

TVA will implement changes to Unit 1 Periodic Inspection program for License Renewal to include inspections of small diameter stainless steel piping/tubing (1/2 inch to 1 inch). Procedure revision and implementation will be completed by October 10, 2012.

110 JOG Class D MOVs for BFN 113967397 ML12272A119 9/25/2012 12/14/2012 12/14/2012 Closed TVA will provide the NRC with the Reported to the following information: Population of NRC BFN identified Class "D" MOVs; Corresponding implementation schedule for completion of modifications to allow classification of the identified Class "D" Motor-Operated Valves as Class "A" or Class "B" 111 The one-time inspection program will NC0040006008 ML040060359 12/31/2003 8/29/2013 Open be implemented and completed prior to the period of extended operation.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 112 A turbine trip/generator load reject NC0070019001 ML072960311 10/22/2007 1/15/2014 Open transient test from nominal EPU rated power conditions will be a turbine trip/generator load reject transient test from nominal EPU rated power conditions will be performed within 60 days of operation at EPU power on Unit 1.--Bcm/Bab 113 ForGE based fuels methods NC0080017001 ML080530256 2/21/2008 1/15/2014 Open applications, The Unit 1 core r-factor calculation at a bundle level will be consistent with the lattice axial void conditions expected for the hot channel operating state. --Bcm/Bab 114 Before applying 1 0 weight percent NC0080017002 ML080530256 2/21/2008 1/15/2014 Open Gadolinium To U1 GE EPU licensing applications, the GE thermal-mechanical (t-m) licensing topical report demonstrating that the t-m acceptance criteria specified in Gestar ii and Amendment 222 To Gestar ii can be met for steady-state and transient conditions must be NRC-approved.

115 ForGE Based Unit 1 EPU fuels NC0080017003 ML080530256 2/21/2008 1/15/2014 Open methods applications, the calibration errors due to bypass voiding will be accounted for determining oscillation I

power range monitor setpoints for the detect and suppress long term methodology.

I Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 116 MOVs will be in compliance with GL 114336733 ML13037A090 1/31/2013 3/15/2014 Open 89-1 0 Program.

The TV A has added the following motor-operated valves (MOVs) to the Generic Letter (GL) 89-10 program.

These MOVs, with the exception of 1-FCV-74-01, 1 FCV 74-02, 1-FCV 19, 2-FCV-71-19, and 3-FCV-71-19, will be in full compliance with GL 89-10 program requirements by the end of the Browns Ferry Nuclear Plant, Unit 2, Spring 2013 refueling outage.

Forvalves 1-FCV-74-01, 1 FCV74-02, 1-FCV-71-19, these MOVs will be in full compliance with GL 89-1 0 program requirements by the end of the Browns Ferry Nuclear Plant, Unit 1, Fall 2014 refueling outage. For valve 2-FCV-71-19, this MOV will be in full compliance with GL 89-1 0 program requirements by the end of the Browns Ferry Nuclear Plant, Unit 2, Spring 2015 refueling outage. For valve 3-FCV-71-19, this MOV will be I

in full compliance with GL 89-10 program requirements by the end of I

the Browns Ferry Nuclear Plant, Unit 3, Spring 2014 refueling outage.

Reg Commitment Summary TVA Document Document Scheduled Completion Commitment Comm Commitment ID Accession No.

Date Due Date Date and Status No.

No Method of Closure 117 The Automatic Depressurization 113108684 (U1) 11/24/2012 11/16/2012 Closed System (ADS) will be modified to provide a single failure proof automatic initiation capability of 4 ADS valves, regardless of which 250VDC batter fails. This modification is expected to be made to BFN, Unit 1, during the Unit 1 outage in the fall of 2012.

118 (U2) TS Change TS-473, AREVA 113108813 (U2)

ML101250173 04/30/2010 4/28/2013 4/17/2013 Closed Fuel Transition Closed by DCN ADS will be modified to provide a 70049A single failure proof automatic initiation capability of 4 ADS valves, regardless of which 250 VDC battery fails.

ML13329A350 OFFICE LPL2-2/

LPL2-2/PM LPL2-2/LA SUMMER INTERN NAME Nlisse FSaba BCiayton DATE N/A 4/1/14 3/31/14