ML14213A033

Audit of the Licensee'S Management of Regulatory Commitments, Audit Performed July 15-17, 2014

ML14213A033
Person / Time
Site:	Comanche Peak
Issue date:	09/02/2014
From:	Balwant Singal Plant Licensing Branch IV
To:	Flores R Luminant Generation Co
Goetz S
References
TAC MF3370, TAC MF3371
Download: ML14213A033 (26)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 2, 2014 Mr. Rafael Flores Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2- AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MF3370 AND MF3371)

Dear Mr. Flores:

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

An audit of Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, commitment management program was performed at the plant site on July 15-17, 2014. The NRC staff concludes, based on the audit, that Luminant Generation Company LLC (the licensee) has implemented NRC commitments on a timely basis, and (2) the licensee has implemented an effective program for managing NRC commitment changes at CPNPP, Units 1 and 2. The details of the audit including the NRC staff's observations and recommendations are set forth in the enclosed audit report.

R. Flores The NRC staff appreciates the resources that were made available by your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-3016.

Sincerely, b~'c-2~~~-

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Audit Report cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446

1.0 INTRODUCTION AND BACKGROUND

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes,"

(ADAMS Accession No. ML003680088) contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. NEI 99-04 describes a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee by a certain date 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.

NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, commitment management program was performed at the plant site on July 15-17, 2014. The audit reviewed commitments made since the previous audit on August 16-17, 2011 (audit report issued on Enclosure

September 23, 2011 (ADAMS Accession No. ML112440514). The audit consisted of three major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments, 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.

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, relief requests, etc.) or licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff searched ADAMS for the licensee's submittals since the last audit and selected a representative sample of regulatory commitments for verification. The identified list of commitments was forwarded to the licensee with a request to locate documentation for the listed regulatory commitments ahead of the NRC staff visit.

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 and Technical Specifications. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results Luminant Generation Company LLC (Luminant, the licensee) has implemented Procedure STA-509, "Commitments Management Program," which identifies the methods and site organization tools for managing development, review, and implementation of station commitments. The licensee's Procedure REG-509, "Nuclear Licensing Commitment Administration," establishes the processes, guidelines, and activities the licensee uses to manage the development, review, and implementation of commitments generated from regulatory obligations and self-imposed requirements. An electronic commitment tracking

system (ECTS) database is used in conjunction with other information sources to address and track regulatory commitments.

The documents furnished by the licensee during the audit included summary sheets from the ECTS database providing the status of the commitments and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation). The NRC staff reviewed the documents and summarized the selected commitments information in the Attachment to this audit report.

The NRC staff's audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.

As discussed above, the ECTS and commitments material change evaluation (CMCE) provided by the licensee's Procedures STA-509 and REG-509, provide acceptable tools for the licensee to capture the NRC guidance on commitment management programs. The licensee enters the regulatory commitments made to the NRC into a database. The regulatory commitments are labeled as regulatory commitments. Each commitment is numbered and described by a commitment title and a brief description. Status of the commitments, implementation dates, target implementation (documents which finally capture the commitment) document information associated with each specific commitment, and comments are captured in the database. The licensee's staff is well trained in updating the commitment management program.

The licensee has maintained the ECTS database very well and all the commitments selected for this audit were traceable in the database. For commitments already incorporated, the database provided an accurate status of the commitment providing reference to the implementation document. The NRC staffs audit of the licensee's commitment management program for CPNPP, Units 1 and 2, did not identify any regulatory commitments that were not satisfied or incorporated except for the ones described below. However, none of the items identified below had any safety significance.

Commitment No. 4356619 For the condition monitoring (CM) assessment, the component of operational leakage from the prior cycle from below the H* distance will be multiplied by a factor of 3.16 and added to the total accident leakage from any other source and compared to the allowable accident induced leakage limit. For the operational assessment (OA), the difference in the leakage between the allowed accident induced leakage and the accident-induced leakage from sources other than the tubesheet expansion region will be divided by 3.16 and compared to the observed operational leakage. An administrative limit will be established to not exceed the calculated value.

Procedure NDE 7.14, "Non Destructive Examination Program Manual" Section 6.1.1.1 was revised to incorporate the commitment. However, the ECTS database did not recognize the procedure revised to incorporate the commitment. The licensee wrote a Condition Report (CR) 2014-007691 on July 1, 2014, to correct the database.

Commitment No. 4408996 Luminant will maintain Spent Fuel Pool boron concentration at or above 2400 ppm [parts per million], above that required for operability as allowed in Technical Specification 3. 7.16, "Fuel Storage Pool Boron Concentration" (2000 ppm).

As per data ECTS database, Data Sheets ODA-308-3.7.16, ODA-308-3.9.1, and ODA-308-3.9.0 for Procedure ODA-308, "LCO [Limiting Conditions for Operation] Tracking Program," were supposed to be revised to incorporate the commitment. The licensee missed revising Data Sheet ODA-308-3.9.0, but closed the commitment. CR 2014-007707 was generated on July 1, 2014, to incorporate the commitment in to Data Sheet ODA-308-3.9.0.

Commitment No. 4392919 Conduct and provide results for an onsite and augmented staffing assessment considering all requested functions except those related to NTTF [Near Term Task Force] Recommendation 4.2. [Phase 1 staffing assessment for Staffing Request 1]

The ECTS database indicates the commitment was closed by letter dated April 30, 2013 (ADAMS Accession No. ML13128A077). However, the letter dated April30, 2013, does not state specifically which commitments were closed. It also does not reference the letter dated June 5, 2012 (ADAMS Accession No. ML12177A055), which made the commitment. There was no corrective action assigned.

Commitment No. 4392934 Provide a schedule of the time needed to implement changes associated with the Phase 1 staffing assessment [for Staffing Request 2].

The ECTS database indicates the commitment was closed by letter dated April 30, 2013 (ADAMS Accession No. ML13128A077). However, the letter dated April30, 2013, does not state specifically which commitments were closed. It also does not reference the letter dated June 5, 2012 (ADAMS Accession No. ML12177A055), which made the commitment. There was no corrective action assigned.

Commitment No. 4392954 Identify changes associated with the Phase 1 staffing assessment that have been _made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all AC [alternating

current] power, multi-unit event, including any new or revised agreements with offsite resource providers [for Staffing Request 6].

The ECTS database indicates the commitment was closed by letter dated April 30, 2013 (ADAMS Accession No. ML13128A077). However, the letter dated April30, 2013, does not state specifically which commitments were closed. It also does not reference the letter dated June 5, 2012 (ADAMS Accession No. ML12177A055), which made the commitment. There was no corrective action assigned.

Commitment No. 4430943 Luminant confirms that it will use the seismic walkdown guidance (EPRI [Electric Power Research Institute] 1025286, "Seismic Walkdown Guidance: For Resolution of Fukushima Near-Term Task Force Recommendation 2.3: Seismic")

as endorsed by Reference 2 to conduct the walkdowns and develop the needed information at CPNPP.

The licensee submitted seismic walkdown report and confirmed that walkdowns were performed consistent with NRC-endorsed EPRI guidance by letter dated November 27, 2012 (ADAMS Accession No. ML12340A433). However, the letter did not make a reference to the original commitment and did not clearly state that it closed the commitment. There was no corrective action assigned.

Commitment No. 4630681 Identify and Integrate into the ERO [Emergency Response Organization]

notification/activation protocol those non-ERO response personnel (e.g.,

Operations and Maintenance) necessary to support expanded response capability functions.

The commitment was scheduled for completion by December 31, 2013, but was changed to May 22, 2014, by the licensee. Emergency Planning (EP) department concludes that CPNPP employs "all-call, all come" approach to ERO response and there was no need to make this commitment and commitment should be closed. However, operations department considers the commitment to be valid. CRs 2014-007478 and 2014-007889 were generated on June 24 and July 3, 2014, respectively, to resolve the concerns by operations. The licensee is in the process of performing an evaluation to determine the need and status of the commitment.

To ensure that the regulatory commitments are not removed or changed in future revisions to the target documents, the licensee performs a database search to identify all the open and closed commitments against the document/procedure being revised and this ensures that all the closed commitments are captured. In addition, the plant procedures require that all the specific regulatory commitments pertaining to the individual document be included in the reference section. This ensures that the commitments, are neither removed nor changed, without management approval.

Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitment management program effectively in accordance with

LIC-1 05, Revision 5, "Managing Regulatory Commitments Made by Licensees to the NRC,"

(ADAMS Accession No. ML13193A358) and consistent with NEI 99-04. The discrepancies identified by the NRC staff are minor in nature and do not have any safety significance.

The Attachment to this audit report contains details of the audit and a summary of the audit results.

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at CPNPP, Units 1 and 2, is contained in Procedures STA-509 and REG-509. The primary focus of the audit was to ensure that the commitments are implemented without a change and if a change is made, it is in accordance with the approved plant procedures and with the approval of the plant's management. The audit also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation.

This ensures that the licensee's personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.2.1 Audit Results Detailed processes are outlined by which the licensee carries out obligations under its regulatory commitments. Any changes to the commitments are processed through the CMCE process. Changes to obligatory commitments are reported to the NRC in accordance with the recommendations of LIC-1 05. CMCE identifies the affected commitments, their origin, original criteria, proposed changes, and justification for change. The commitment changes are documented in CMCE forms for submittal to the NRC staff.

The licensee performed an ECTS database search and provided a list of commitment changes made since the last audit. The list contained a total of 66 items, identified as commitment changes. However, the NRC staff review indicated that majority of the items on the list were changes to the internal commitment dates and did not represent a change to the Regulatory Commitment date. The NRC staff identified only five commitment changes and only one of these required the NRC staff notification.

Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented regulatory commitment changes appropriately, in accordance with LIC-105 and consistent with NEI 99-04. However, a weakness in the ECTS database to identify regulatory commitments changes not internal to the licensee was identified. The licensee agreed to modify the ECTS database fields to ensure that regulatory commitment changes are adequately captured during the search.

2.3 Verification that Reviewed Regulatory Commitments were Correctly Applied in NRC Staff Licensing Action Reviews 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. Based on the NRC staff review of the safety evaluations and staff assessments issued for the audit period, it was determined that the commitments reviewed by the NRC staff were explicit statements made by the licensee to take specific action in support of the specific licensing action and were correctly applied while reviewing the licensing actions.

3.0 OBSERVATIONS AND RECOMMENDATIONS A weakness in the ECTS database to identify regulatory commitments changes not internal to the licensee was identified. From a list of 66 commitment changes identified by the database search, only five were actual regulatory commitment changes. The licensee agreed to modify the ECTS database fields to ensure that regulatory commitment changes are adequately captured during the search.

During the audit in 2011, the NRC staff noticed that the ECTS database does not include a field to state the closing date for the commitment and recommended that ECTS database should include an additional field to clearly state the commitment closing date. The licensee generated CR-2011-01 0459 on September 23, 2011 to address the NRC staff concern. The CR was closed on March 3, 2012 with no change to the ECTS database. The licensee staff was unable to provide a justification for closing the CR without any change to the ECTS database during the audit and generated another CR-2014-008661 on August 4, 2014 to address the NRC staff concern.

4.0 CONCLUSION

Based on the results of the audit, the NRC staff concludes that the licensee has implemented the regulatory commitment management program effectively, and implemented regulatory commitment changes appropriately, in accordance with LIC-1 05 and consistent with NEI 99-04.

The specific observations and recommendations identified during the audit are detailed in Section 3.0 of the report.

5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Tamera Ervin-Walker and Steve Dixon.

Principal Contributor: Balwant K. Singal Date: September 2, 2014

Attachment:

Regulatory Commitments and Summary of Audit Results

REGULATORY COMMITMENTS AND

SUMMARY

OF AUDIT RESULTS COMANCHE PEAK NUCLEAR POWER PLANT AUDIT PERFORMED FROM July 15-17, 2014 Commitment letter No. Subject No. Description of Commitment Implementation Status TXX-13091 , dated Closure 4641403 Within six months of establishing a final determination of the Open. The PWROG testing programs for in-May 16,2013 Options for scope of insulation replacement or remediation (if required), vessel effects are scheduled to be submitted (ADAMS Generic Safety Luminant Generation Company LLC (Luminant) will submit a final to the NRC staff for review by December Accession No. Issue 191 updated supplemental response to support closure of GL 2004-02 2014. The NRC staff safety evaluation is ML13149A101) (GSI-191) for Comanche Peak. If no modifications are required, the expected to be issued by December 2015. If submittal will be made three months after the NRC approval of the no plant modifications are required,Luminant PWR Owners Group (PWROG) testing programs for in-vessel will make the submittal within three months of effects and completion of the final bypass test reports. the NRC approval. If plant modifications are required, Luminant will make the submittal within six months of establishing a final determination of the scope of insulation replacement. Hence, the commitment is still open and the final closure is expected by December 1, 2015.

4641431 Luminant will update the current licensing basis (UFSAR) Open. The closure of this commitment is following NRC acceptance of the updated supplemental response based on closure of Commitment No.

for Comanche Peak and completion of any identified removal or 4641403. Luminant revised the completion modification of insulation debris sources in containment per plant date as follows:

modification procedures and processes in accordance with 10 CFR 50.71 (e). February 1, 2016 (if no plant modifications are required).

February 1, 2017 (if insulation removal is required).

NRC Letter dated License 4356629 Luminant commits to monitor for tube slippage as implementation Closed. Section 6.1.6 was added to October 18, 2012 Amendment of Amendment part of the steam generator tube inspection Procedure NDE 7.1,0 "CPNPP [Comanche (ADAMS Request (LAR) program. Slippage monitoring will occur for each inspection of Peak Nuclear Power Plant] Nondestructive Accession No. for Changes to the Comanche Peak Unit 2 steam generators. Examination Program Manual" to monitor for ML12263A036) Technical Tube slippage as part of Steam Generator Specifications Inspection Program. In addition, 5.5.9 and Section 6.1.22 was added to Procedure NDE 5.6.9 - 7.13, "CPNPP nondestructive Examination Alternate Program Manual" as an essential element for Steam developing degradation assessment Generator associated with steam generators.

Repair Criteria Attachment

Commitment Letter No. Subject No. Description of Commitment Implementation Status 4356619 For the condition monitoring (CM) assessment, the component of Closed. The commitment was closed, but the operational leakage from the prior cycle from below the H* Electronic Commitment Tracking System distance will be multiplied by a factor of 3.16 and added to the (ECTS) database did not recognize the total accident leakage from any other source and compared to the procedures which incorporated the allowable accident induced leakage limit. For the operational commitment. Luminant wrote a Condition assessment (OA), the difference in the leakage between the Report (CR) 2014-007691 on July 1, 2014 to allowed accident induced leakage and the accident induced correct the database. Procedure NDE 7 .14, leakage from sources other than the tubesheet expansion region "Non Destructive Examination Program will be divided by 3.16 and compared to the observed operational Manual" was revised to incorporate the leakage. An administrative limit will be established to not exceed commitment. Specifically Section 6.1.1 1 was the calculated value. added to state, "Obtain operational leakage for current cycle from procedure COP-732 (Ref 3.8). Conservatively assign all leakage to be from below H* elevation."

Procedure number COP-732, "Chemistry Operating Procedures Manual" Section 4.1 I was also updated to include the commitment. I NRC Letter Confirmatory 4494908 Any discharged fuel irradiated under up-rate power conditions frorr Closed. The commitment was incorporated '

October 22, 2012 Action Letter (Stated as Unit 2 Cycle 13 and later and Unit 1 Cycle 16 and later, will be in to the following procedures:

(ADAMS (4-12-004)- Commitment restricted to storage in the Region I storage racks until the NRC Accession No. Comanche No. 1 in the approves a license amendment revising Technical Specification Procedure No. NUC-211, "SFP Storage ML12296A937) Peak Nuclear Letter) 3.7.17, "Spent Fuel Storage," authorizing storage in Region II Limitations for Reactivity Control" and Power Plant, storage racks. Procedure No. RF0-1 06, "Development and Units 1 and 2, Implementation of Fuel Shuffle Sequence Commitments Plans." Hence, following the revision to the Regarding plant procedures, the commitment was Spent Fuel closed. Luminant submitted the revised spent Pool Storage fuel criticality analysis license amendment Practices request (LAR) for storage of the up rated fuel in Region II of the pool by letter dated March 28, 2013 (ADAMS Accession No. ML13095A023) and the LAR was approved by the NRC on July 1, 2014 (ADAMS Accession No. ML14160A035).

Hence, all the actions associated with this commitment are complete.

Commitment letter No. Subject No. Description of Commitment Implementation Status 4494910 Luminant will retain the Region II spent fuel storage racks in both Closed. Luminant revised Procedure No.

(Stated as spent fuel pools 1 and 2 in the current as-loaded configuration as RF0-106, "Development and Implementation Commitment of October 11, 2012 for both fuel assemblies and fuel assembly of Fuel Shuffle Sequence Plans," to No.2 in the inserts (excluding thimble plugging devices). If configuration incorporate the commitment. The Letter) changes are required, plans for the changes will be commitment was closed after it was communicated to the NRC Region IV Regional Administrator in incorporate in to the Procedure.

advance.

4494911 Luminant will prepare and submit a license amendment to revise Closed. Luminant submitted the LAR by (Stated as Technical Specification 3.7.17, "Spent Fuel Assembly Storage" letter dated January 15, 2013 (ADAMS Commitment with the current spent fuel pool configurations with fuel discharged Accession No. ML13032A240) to address the No.3 in the from reactor operation at up-rate conditions (3612 Megawatt existing spent fuel storage configuration at the Letter) Thermal). The schedule for submittal of this license amendment time of the submittal. Later, the licensee is January 15, 2013. submitted the revised SFP criticality analysis by letter dated March 28, 2013 for approval of spent fuel storage configurations in Region II of the pool and the LAR dated January 15, 2013 was withdrawn.

4408996 Luminant will maintain Spent Fuel Pool boron concentration at or Closed. The following documents were (Stated as above 2400 ppm, above that required for operability as allowed in revised to incorporate this commitment:

Commitment Technical Specification 3.7 .16, "Fuel Storage Pool Boron

• Procedure No. CHM-120, "Primary No.4 in the Concentration" (2000 ppm). Chemistry."

Letter)

• Procedure No. RF0-1 02, "Refueling Operations."

• Procedure No. SOP-506, "Spent Fuel Pool Cooling and Cleanup System."

• Procedure No. ODA-308, "LCO Tracking Program, "Following data sheets were revised:

ODA-308-3.7.16 ODA-308-3.9.1 Data sheet ODA-308-3.9.0 was also supposed to be revised to incorporate the commitment, but was missed. CR-2014-007707 was generated on July 1, 2014 to incorporate the commitment in to data sheet ODA-308-3.9.0.

Commitment Letter No. Subject No. Description of Commitment Implementation Status I TXX-11 043, Dated Request for 3834209 Implement all cyber security related modifications (outage and Open. All plant modifications were originally March 31, 2011 Review and non-outage) and enter the maintenance phase of the NRC scheduled to be completed by March 31, (ADAMS Approval of approved Cyber Security Program by March 31, 2015. 2015. However, Luminant has requested an Accession No. Cyber Security extension to the final implementation date to ML110940055) Plan June 30, 2017 by letter dated November 21, 2013 (ADAMS Accession No. ML13338A436) and commitment date to enter the maintenance phase will be revised after the amendment request is approved.

TXX-12149, dated Application for 4484874 Luminant Holding Company LLC, the parent company of Luminant Closed. Luminant submitted the support October 11, 2012 Order Power, provided Luminant Power with a support agreement in the agreement between Luminant Holding (ADAMS Approving amount of $250 million in 2007. In connection with the proposed Company and Luminant Generation company Accession No. Indirect and transaction, Luminant Power proposes to increase the amount dated Apri115, 2013.

ML12312A157) Internal available under this support agreement to $300 million, which Transfer of provides a source of funding in an amount that is adequate to fund Licenses approximately one year's worth of the average projected expense for the fixed operations and maintenance (O&M) of CPNPP. _____j

Commitment Letter No. Subject No. Description of Commitments Implementation Status NRC Letters dated LAR for 4441997 Commitments Associated with the 138kV Work Closed. Luminant issued the following September 18, Revision to TS training procedures in support of this 2013 (ADAMS 3.8.1 for Two During a 14-day Completion Time (CT}, the Alternate Power commitment:

Accession No. 14-Day Diesel Generator (APDG) provided for each Unit will be verified ML13232A143 Completion available to provide power to equipment for long term cooling

• MD01.FDA.APG, "Alternate Power and Luminant Times for once per shift. Generator Refueling JIT [Just in-Time Letter TXX-131 56, Offsite Circuits Training]"

dated October 24,

• MR01.FDA.XIA, "XST1A Transformer 2013 (ADAMS Modification JIT,"

Accession No.

• OPD1.C13.1R4, "Cycle 13-3 Design ML133088905) Modifications and Current Events."

• OPD1.013.1R4, "Cycle 13-4 Design Modifications and Current Events."

• POB4APGEG2, "Auxiliary Power Generators."

• Defense in Depth Contingency Plan DIDCP No. XST-01, "Loss of Offsite Power and Station Blackout during XST1 Maintenance."

Part of the modification was implemented.

However, the licensee ended up cutting the wrong cable during implementation and had to abandon the rest of the modification on October 22, 2013. The NRC staff approval for extension of LCO 3.8.1 expired on March 31, 2014. Luminant has submitted a new LAR dated July 1, 2014 (ADAMS Accession No. ML14192A338 for completing rest of the modification. Hence, the commitment has been closed.

4456419 During a 14-day CT, if an APDG becomes unavailable, both units Closed. Same as Commitment No. 4456419.

shall enter Condition C of TS 3.8.1 and start shutting down within 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />. (This 24-hour period will only be allowed once within a 14-day CT). I 4442002 Prior to initiation of a one time, 14-day CT extension, preventive Closed. Same as Commitment No. 4456419.

maintenance (PM) task for breakers 1EA1-1, 1EA2-1, 2EA1-1 and 2EA2-2 will be verified as current.

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4442007 Testing of Emergency Diesel Generators (EDGs), APDGs, and Closed. Same as Commitment No. 4456419.

Turbine-Driven Auxiliary Feedwater Pumps( TDAFWPs) will occur within the two (2) weeks prior to the start of the XST1 CT.

4442008 The EDGs, APDGs, TDAFWPs, XST2, Component Cooling Water Closed. Same as Commitment No. 4456419.

Pump (CCWPs), and Station Service Water Pumps (SSWPs) will have ALL testing and maintenance activities suspended for the duration of a one-time, 14-day CT for XST1. Additionally, signs will be placed on the doorways to the equipment, or in the case of XST2 around the equipment, noting the restriction of testing and maintenance during this XST1 CT.

4442010 A roving hourly fire watch will be in effect during the 14-day XST1 Closed. Same as Commitment No. 4456419.

CT along the path of the XST2 power and control cabling. This is an additional measure to monitor the area for fires that could damage and disable the XST2 transformer cabling.

4442011 Local weather conditions and forecasts will be monitored by Closed. Same as Commitment No. 4456419.

Operations twice per shift to assess potential impacts on plant conditions.

4442013 A time in which severe weather is not expected will be selected for Closed. Same as Commitment No. 4456419.

implementation of the XST1 CT. Based on historical information; this time frame is September 1 through March 31. This planned timing will reduce high wind/tornados and weather challenges to the plant during the XST1 CT.

4442016 The seismic walkdown will be completed prior to the XST1 CT to Closed. Same as Commitment No. 4456419.

identify any issues that could impact the EDGs and TDAFWPs during a seismic event. These impacts include mounting or interactions issues including loose parts and missing hardware.

This walkdown is for assurance that these components will meet their seismic design criteria in the event of a seismic incident.

4442028 Access to both switchyards and relay houses will be controlled Closed. Same as Commitment No. 4456419.

and posted, and all maintenance will be suspended for the duration of the CT on XST1.

4442046 CPNPP's Operations Department will contact the Transmission Closed. Same as Commitment No. 4456419.

Operator (Transmission Grid Controller) once per day during a 14-day Completion Time to ensure no problems exist in the transmission lines feeding CPNPP or their associated switchyards that would cause post trip switchyard voltages to exceed the L___

voltage required by STA-629. . L__

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4442047 Just-in-time training for affected work groups will be completed Closed. Same as Commitment No. 4456419.

prior to the start of a XST1 outage.

4442049 All hot work activities along the routing associated with power and Closed. Same as Commitment No. 4456419.

control cabling for XST2, the in-service ST, will be suspended during the XST1 CT. This is to reduce the likelihood of fires that could damage and thus disable the XST2 transformer cabling.

4456879 In the two weeks prior to the start of the CT, a thermographic Closed. Same as Commitment No. 4456419.

survey will be conducted on the two fixed sources in the safeguards switchgear room to verify no abnormalities exist. This is to reduce the likelihood of a fire ignition.

4457002 Both Unit 1 and 2 Transient Combustible safe zones that are Closed. Same as Commitment No. 4456419.

associated with the cable routing for the XST2 transformer will have additional restrictions relating to combustible storage during the extended CT durations. Implementing this mitigation measure will reduce the likelihood of fires related to the XST2 transformer.

Commitments Associated With The 6.9kV Work 4457004 During a 14-day CT, the APDG provided for each Unit will be Closed. Same as Commitment No. 4456419.

verified available to provide power to equipment for long term cooling once per shift.

4457005 During a 14-day CT, if an APDG becomes unavailable, the Closed. Same as Commitment No. 4456419.

affected Unit shall enter Condition C of TS 3.8.1 and comply with the Required Actions. If the CT for the Condition C Required Actions is not met, then Condition G of TS 3.8.1 shall be entered.

This allowance will only be exercised once within a 14-day CT for a given Unit. For any second, or subsequent, unavailability of an APDG for a given Unit, the affected Unit shall immediately enter TS 3.0.3. In all cases, the normal rules governing application of TSs in section 1.0 of the CPNPP TSs shall apply (Revised by Luminant letter dated October 24, 2013).

4457007 Prior to initiation of the one time, two CT extensions, PM task for Closed. Same as Commitment No. 4456419.

breakers 1EA 1-1, 1EA2-1, 2EA 1-1 and 2EA2-2 will be verified as current.

4457008 Testing of EDGs, APDGs, and TDAFWPs will occur within the two Closed. Same as Commitment No. 4456419.

(2) weeks prior to the start of the XST1 CT.

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4457016 The EDGs, APDGs, TDAFWPs, XST2, CCWPs, and SSWPs will Closed. Same as Commitment No. 4456419.

have ALL testing and maintenance activities suspended for the duration of a one-time, 14-day CT for XST1. Additionally, signs will be placed on the doorways to the equipment, or in the case of XST2 around the equipment, noting the restriction of testing and maintenance during this XST1 CT.

4457030 A roving hourly fire watch will be in effect during the 14-day XST1 Closed. Same as Commitment No. 4456419.

CT along the path of the XST2 power and control cabling. This is an additional measure to monitor the area for fires that could damage and disable the XST2 transformer cabling.

4457033 Local weather conditions and forecasts will be monitored by Closed. Same as Commitment No. 4456419.

Operations twice per shift to assess potential impacts on plant conditions.

4457041 A time in which severe weather is not expected will be selected for Closed. Same as Commitment No. 4456419.

implementation of the XST1 CT. Based on historical information; this time frame is September 1 through March 31. This planned timing will reduce high wind/tornados and weather challenges to the plant during the XST1 CT.

4457044 The seismic walkdown will be completed prior to the XST1 CT to Closed. Same as Commitment No. 4456419.

identify any issues that could impact the EDGs and TDAFWPs during a seismic event. These impacts include mounting or interactions issues including loose parts and missing hardware.

This walkdown is for assurance that these components will meet their seismic design criteria in the event of a seismic incident.

4457119 Access to both switchyards and relay houses will be controlled Closed. Same as Commitment No. 4456419.

and posted, and all maintenance will be suspended for the duration of the CT on XST1.

4457121 CPNPP's Operations Department will contact the Transmission Closed. Same as Commitment No. 4456419.

Operator (Transmission Grid Controller) once per day during a 14-day Completion Time to ensure no problems exist in the transmission lines feeding CPNPP or their associated switchyards that would cause post trip switchyard voltages to exceed the voltage required by STA-629.

4457122 Just-in-time training for affected work groups will be completed Closed. Same as Commitment No. 4456419.

prior to the start of a XST1 outage.

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4457123 All hot work activities along the routing associated with power and Closed. Same as Commitment No. 4456419.

control cabling for XST2, the in-service ST, will be suspended during the XST1 CT. This is to reduce the likelihood of fires that could damage and thus disable the XST2 transformer cabling.

4457124 In the two weeks prior to the start of the CT, a thermographic Closed. Same as Commitment No. 4456419.

survey will be conducted on the two fixed sources in the safeguards switchgear room to verify no abnormalities exist. This is to reduce the likelihood of a fire ignition.

4457125 Both Unit 1 and 2 Transient Combustible safe zones that are Closed. Same as Commitment No. 4456419.

associated with the cable routing for the XST2 transformer will have additional restrictions relating to combustible storage during the extended CT durations. Implementing this mitigation measure will reduce the likelihood of fires related to the XST2 transformer.

TXX-12146, dated 30-Day Report 4496945 The peaking factor burndown used in the fuel pellet thermal Open. Waiting for NRC to approve new October 18, 2012 for Significant conductivity evaluation will be added to the Reload Safety ECCS evaluation model.

(ADAMS Change in Analysis Checklist for validation as part of the reload design Accession No. Peak Clad process.

ML 1231 OA058) Temperature .

4496966 Luminant will submit to the NRC, for review and approval, a Open. Waiting for NRC to approve new Large Break Loss-of-Coolant Accident (LBLOCA) analysis that ECCS evaluation model applies NRC-approved methods that include the effects of fuel pellet thermal conductivity.

TXX-13169, dated Spent Fuel 4753383 The BORAL Monitoring Program ensures that: Open. The commitments are associated with November 26, Pool Criticality implementation of the LAR for revised spent 2013 (ADAMS Analysis - (a) future coupons removed for testing are reinserted into the fuel pool criticality analysis approved by the Accession No. LAR to Revise spent fuel pool (SFP) after testing is complete, (b) location and NRC staff by letter dated July 1, 2014 ML13346A175) move times are tracked for the samples (to enable demonstration (ADAMS Accession No.ML14192A338). The TSs 3.7.16, 3 .. 7.17, 4.3, of the total duration that test coupons were removed from the pool licensee is expected to implement the LAR AND 5.5 environment), and (c) includes a requirement to perform continual during fall Unit 1 refueling outage.

testing every 10 years as long as the Region I storage racks are licensed to store fuel.

4753402 BORAL is credited in the Region I racks for both the borated and Open. Same as Commitment No. 4760732.

non-borated cases. The BACKGROUND section of the TS Bases B 3.7.16, 4th paragraph, 1st sentence will be changed to state:

"In order to maintain keff less than or equal to 0.95, the presence of fuel pool soluble boron is credited for the storage of fuel assemblies within the Region I and Region II racks (in addition to the BORAL neutron absorber material in Region 1)."

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4753403 The supporting Criticality Safety Analysis demonstrated Keff Open. Same as Commitment No. 4760732.

remains LESS THAN 1.0 for all analyzed conditions (reference WCAP-17728-P Rev 1 section 2.1.1 ). The BACKGROUND section of the TS Bases B 3. 7 .16, 3rd paragraph, last sentence will be changed to state: "The neutron absorber material BORAL is credited for the storage of spent fuel assemblies within the Region I racks to maintain Keff less than 1.0 at 0 ppm soluble boron concentration."

TXX-13182, dated LAR Spent 4760732 Current and future fuel assemblies will use a Wet Annular Open. The commitments are associated with December 17, Fuel Pool Burnable Absorber (WABA) which is no more than 120 inches in implementation of the LAR for revised spent 2013 (ADAMS Criticality length and 95/95 Upper Bound fuel theoretical density (% TD) will fuel pool criticality analysis approved by the Accession No. Analysis- be< 96.5%. Future fuel cycles will utilize a Maximum Inlet NRC staff by letter dated July 1, 2014 ML14016A131) Response to Temperature of< 561.7 degrees F. If these parameters are not (ADAMS Accession No.ML14192A338). The Requests for met, the fuel assemblies will be treated as fresh fuel for storage in licensee is expected to implement the LAR Additional the Spent Fuel Pools. during fall Unit 1refueling outage.

Information 4760737 CPNPP will review the calculated B-1 0 concentration in the RCS Open. Same as Commitment No. 4760732.

Round 2 each refueling outage (after berating to >2400 ppm, but not including the fill of the Refueling Cavity). If the calculated value is below 0.194 atom fraction, a B-1 0 measurement will be performed on the Spent Fuel Pool after adequate mixing time has occurred, but prior to the next refueling outage to ensure the B-1 0 value in the SFP has not significantly changed.

4760738 CPNPP will review the SFP Boron Measurement history each Open. Same as Commitment No. 4760732.

refueling outage. If the SFP boron values have experienced any increase of more than 100 ppm, a review of B-1 0 values for Boric Acid purchased at CPNPP will be performed. If this review demonstrates that boric acid has been purchased which has a B-10 atom fraction below 0.194, a B-10 measurement will be performed on the Spent Fuel Pool prior to the next refueling outage to ensure the B-1 0 value in the SFP has not significantly changed.

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4760741 For fuel assemblies which are classified as outlier assemblies Open. Same as Commitment No. 4760732.

solely due to Hot Full Power (HFP) Rodded Operation, burnup which is accrued during HFP rodded conditions will not be credited in the Technical specification Surveillance, but all other burnup accrued during the cycle will be credited. The administrative controls and Configuration Confirmation Software tools described in Enclosure 1 of LAR 13-01 will incorporate limitations to ensure that the appropriate burnup is credited for fuel assemblies which have experienced HFP Rodded Operation beyond the low threshold required by the area of applicability.

TXX-12089, dated 90-Day 4414380 Emergency Response Organization (ERO) self-activation Closed. The training slides for Procedure June 7, 2012 Response to expectations will be included in the 2012 ERO annual EP38.ERO.EP1, dated 11/08/2012, describe the self activation expectations and have been 1

(ADAMS March 12, requalification training given to all ERO personnel.

Accession No. 2012 incorporated in to the procedure ..

ML12167A242) Information 4414400 To assist the ability of augmentation staff to reach the site, Closed. By letter dated June 6, 2012 TXDPS Request CPNPP is revising the existing letter of agreement (LOA) with the agreed to assist CPNPP augmentation staff in Regarding Texas Department of Public Safety (TXDPS) specifically to obtain reaching the site in the event of a large scale Recommendat logistical support for the transport of emergency responders to the natural disaster which inhibits site access by ion 9.3 of site in the event of a large-scale natural disaster that inhibits site assistance with logistical support. Luminant Near-Term access. did not have possession of the letter from Task Force TXDPS at the time of the commitment.

(NTTF)

TXX-12096, dated Review of 60- 4392894 Provide an assessment of the current communications systems Closed. The requested information was June 5, 2012 Day Response and equipment used during an emergency event to identify any provided by the licensee by letter dated (ADAMS to Request for enhancements that may be needed to ensure communications October 31, 2012 (ADAMS Accession No.

Accession No. Information are maintained during a large scale natural event meeting the ML12318A100).

(ML12177A055) Regarding conditions described.

Recommendat 4392918 Provide an implementation schedule of the time needed to Closed. Same as Commitment No. 4392894.

ion 9.3 of the conduct and implement the results of the communications NTTF (Near assessment.

Term Task Force) 4392919 Conduct and provide results for an onsite and augmented staffing Closed. ECTS database indicates letter assessment considering all requested functions except those dated April 30, 2013 (ADAMS Accession No.

related to NTTF Recommendation 4.2. (Phase 1 staffing ML 13128A07) closed it. However, letter assessment for Staffing Request 1] dated April 30, 2013 does not state what commitments were closed. It also does not reference the letter dated June 5, 2012, which made the commitment.

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4392932 Conduct and provide results for an onsite and augmented staffing Open. The commitment was originally assessment considering functions related to NTTF scheduled to be completed by June 1, 2014.

Recommendation 4.2. [Phase 2 staffing assessment for Staffing By letter dated May 15, 2014 (ADAMS Request 1] Accession No. ML14143A400), the licensee changed the commitment completion date to June 1, 2015 .

4392934 Provide a schedule of the time needed to implement changes Closed. Database indicates letter dated April associated with the Phase 1 staffing assessment [for Staffing 30, 2013 (ADAMS Accession No.

Request 2]. ML 13128A07) closed it. However, letter dated April 30, 2013 does not state what commitments were closed. It also does not reference the letter dated June 5, 2012, which made the commitment.

4392952 Provide a schedule of the time needed to implement changes Open. The commitment was originally associated with the Phase 2 staffing assessment. [for Staffing scheduled to be completed by June 1, 2014.

Request 2] By letter dated May 15, 2014 , (ADAMS Accession No. ML14143A400) the licensee changed the commitment completion date to June 1, 2015.

4392954 Identify changes associated with the Phase 1 staffing assessment Closed. Database indicates letter dated April that have been made or will be made to your emergency plan 30, 2013 (ADAMS Accession No.

regarding the on-shift or augmented staffing changes necessary ML13128A07) closed it. However, letter to respond to a loss of all AC power, multi-unit event, including dated April 30, 2013 does not state what any new or revised agreements with offsite resource providers [for commitments were closed. It also does not Staffing Request 6]. reference the letter dated June 5, 2012, which made the commitment.

4392956 Identify changes associated with the Phase 2 staffing assessment Open. The commitment was originally that have been made or will be made to your emergency plan scheduled to be completed by June 1, 2014.

regarding the on-shift or augmented staffing changes necessary By letter dated May 15, 2014, (ADAMS to respond to a loss of all AC power, multi-unit event, including Accession No. ML14143A400) the licensee any new or revised agreements with offsite resource providers [for changed the commitment completion date to Staffing Request 6]. June 1, 2015.

Commitment Letter No. Subject No. Description of Commitments Implementation Status TXX-12108, dated 120-Day 4430943 Luminant confirms that it will use the seismic walkdown guidance Closed. The licensee submitted seismic July 10, 2012 Response to (EPRI [Electric Power Research lnstitute]1 025286, "Seismic walkdown report and confirmed that (ADAMS NRC Request Walkdown Guidance: For Resolution of Fukushima Near-Term walkkdowns were performed consistent with Accession No. for Information Task Force Recommendation 2.3: Seismic") as endorsed by NRC-endorsed EPRI guidance by letter dated ML12201A095) Pursuant to 10 Reference 2 to conduct the walkdowns and develop the needed November 27, 2012 (ADAMS Accession No.

CFR 50.54(f) information at CPNPP. ML12340A433). However, the letter did not Regarding the make a reference to the original commitment Seismic and did not clearly state that it closed the Aspects of commitment. In addition, the licensee was Recommendat unable to complete walkdowns for some of ion 2.3 of the the inaccessible areas for Unit 1 and made a NTTF Review new commitment (Commitment No. 4527482) of the NTTF to complete rest of the walk downs by June 30, 2013.

TXX-12178 and 120-Day 4527482 Luminant will complete the seismic walkdowns for CPNPP Unit 1 Closed. The licensee submitted the final TXX-131 05, dated Response to during 1FR 16 in the Spring of 2013 and submit a supplemental walkdown report for the inaccessible areas for November 27, NRC Request report by June 30, 2013. Unit 1 by letter dated July 1, 2013 (ADAMS 2012 and July 1, for Information Accession No. ML13192A179).

2013 (ADAMS Pursuant to 10 Accession Nos. CFR 50.54(f)

ML13009A269 Regarding the and Seismic ML13129A179) Aspects of Recommendat ion 2.3 of the NTTF Review of the NTTF TXX-13081 , dated Response to 4630659 Integrate the expanded response capability into existing Open. The commitment is scheduled for April 30, 2013 March 12, augmented Emergency Response Organization (ERO) processes completion by October 31, 2014.

(ADAMS 2012 Request (i.e., the ability to transition from a single-unit to a multi-unit Accession No. for Information expanded response capability).

ML13128A077) Pursuant to 10 4630672 Develop plans/procedures that address the use of expanded Open. The commitment is scheduled for CFR 54(f) response capability in the on-site/near-site primary and alternate completion by October 31, 2014.

Regarding emergency response facilities (e.g., OSC and TSC) for declared Recommendat emergency events that involve more than one-unit at multi-unit ions of the sites. This should include the relocation of expanded response NTTF capability to the alternate emergency response facility, should the primary emergency response facility be rendered inoperable. -

Commitment Letter No. Subject No. Description of Commitments Implementation Status 4630681 Identify and Integrate into the ERO notification/activation protocol Open. The commitment was scheduled for those non-ERO response personnel (e.g., Operations and completion by December 31, 2013. The Maintenance) necessary to support expanded response capability commitment completion date was changed to functions. May 22, 2014 by the licensee. Emergency Planning (EP) department concludes that CPNPP employs "all-call, all come" approach to ERO response and there was no need to make this commitment and commitment should be closed. However, operations department concludes that the commitment is valid and should be incorporated in to the plant procedures. CRs 2014-007478 and 2014-007889 were generated on June 24 and July 3, 2014, respectively to resolve the concerns by operations. The licensee is in the process of performing an evaluation to determine the need and status of the commitment.

TXX-14067, dated 60-Day 4392932 Conduct and provide results for an onsite and augmented Open. The licensee changed the completion May 15,2014 Revised staffing assessment considering functions related to NTTF date to 4 months prior to beginning of 2RF15 (ADAMS Response to Recommendation 4.2. [Phase 2 staffing assessment for Staffing refueling outage (estimated June 2015).

Accession No. NRC Request Request 1]

ML14143A400) for Information I Pursuant to Open. The licensee changed the completion 4392952 Provide a schedule of the time needed to implement changes 10 CFR associated with the Phase 2 staffing assessment [for Staffing date to 4 months prior to beginning of 2RF15 50.54(f)

Request 2] refueling outage (estimated June 2015).

Regarding Recommendat 4392956 Identify changes associated with the Phase 2 staffing assessment Open. The licensee changed the completion ion 2.1, 2.3 that have been made or will be made to your emergency plan date to 4 months prior to beginning of 2RF15 '

and 9.3 of the regarding the on-shift or augmented staffing changes necessary refueling outage (estimated June 2015).

Near-Term to respond to a loss of all AC power, multi-unit event, including Task Force any new or revised agreements with offsite resource providers [for Review of the Staffing Request 6]

Insights from the Fukushima Dai-lchi Accident, Dated March 12, 2012

Commitment Letter No. Subject No. Description of Commitments Implementation Status '

TXX-14061, dated LAR 13-01 4844167 Following implementation of the PETRIFIED software, Luminant Open. The commitments are associated with May 1, 2014 Spent Fuel Power will operationally verify (independent of PETRIFIED implementation of the LAR for revised spent (ADAMS Criticality calculations) the TS 3.7.17 categorization calculations for fuel fuel pool criticality analysis approved by the Accession No. analysis, discharged from Unit 2 Cycle 14 and Unit 1 Cycle 17 prior to NRC staff by letter dated July 1 2014 (ADAMS ML14136A027) supplemental storing these assemblies in Region II. CPNPP will further Accession No. ML14192A338). The licensee information to operationally verify (independent of PETRIFIED) fuel movement is expected to implement the LAR during fall requests for plans which impact Region II during 2014, to ensure the allowed Unit 1 refueling outage.

additional configurations ofTS 3.7.17 are maintained. Fuel movement plans information which impact Region II include movement of fuel into Region II as well as fuel movement within Region II (reconfiguration). These operational verification activities will be performed by an individual independent of the software developer and the developer of the initial PETRIFIED test plan, but maintains at least the same level L _ _ _ _____

of qualific_~ti()_n. -- -*

ML14213A033 OFFICE NRRIDORL/LPL4-1 /PM NRRIDORLILPL4-1 /PM NRRIDORLILPL4-1 /LA NAME SGoetz BSingal JBurkhardt DATE 8/4/14 8/1/14 8/1/14 OFFICE NRRIDORLILPL4-1/BC (A) NRRIDORL/LPL4-1 /PM NAME EOesterle (CFLyon for) BSingal DATE 9/2/14 9/2/14