ML14353A367

Audit of the Licensees Management of Regulatory Commitments

ML14353A367
Person / Time
Site:	Perry  (NPF-058)
Issue date:	01/05/2015
From:	Dietrich A Plant Licensing Branch III
To:	Kaminskas V FirstEnergy Nuclear Operating Co
Dietrich A
References
TAC MF5186
Download: ML14353A367 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Vito Kaminskas Site Vice President January 5, 2015 FirstEnergy Nuclear Operating Company Mail Stop A-PY -A290 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT N0.1 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF5186)

Dear Mr. Kaminskas:

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, "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, that changes to the regulatory commitments are evaluated, and when appropriate, reported to the NRC.

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

An audit of the Perry Nuclear Power Plant, Unit 1 (PNPP) commitment management program was performed at the plant site on December 10 and 11, 2014. The NRC staff concludes, based on the audit, that FirstEnergy Nuclear Operating Company (the licensee) has implemented NRC commitments on a timely basis, and that the licensee has implemented an effective program for managing NRC commitment changes at PNPP. The details of the results of the audit are set forth in the enclosed audit report.

There is no need for the licensee to respond to this letter. The NRC staff appreciates the resources that were made available by your staff during the audit. If you have any questions, please contact me at (301) 415-2846.

Docket No. 50-440

Enclosure:

Audit Report cc w/encl: Distribution via Listserv Sincerely, Allison W. Dietrich, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS FIRST ENERGY NUCLEAR OPERATING COMPANY PERRY NUCLEAR POWER PLANT. UNIT 1 DOCKET NO. 50-440

1.0 INTRODUCTION AND BACKGROUND

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. NEI 99-04 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 three years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented. An audit of the Perry Nuclear Power Plant, Unit 1 (PNPP) commitment management program was performed at the plant site on December 10 and 11, 2014. The audit reviewed commitments made, changed, or closed since the previous audit on December 13 and 14, 2011.

NRR guidelines direct the 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 (i.e., amendments, reliefs, exemptions, etc.) and activities (i.e., bulletins, generic letters, etc.).

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

2.1 Verification of Licensee's Management and Implementation of 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 and activities. For Enclosure 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 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 (i.e., amendments, exemptions, etc.), or licensing activities (i.e.,

bulletins, generic letters, etc.). Commitments made in licensee event reports or in response to Notices of Violation may be included in the sample, but the review will be limited to verification of restoration of compliance, not the specific methods used. Before the audit, the NRC staff searched ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification.

The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations and technical specifications.

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

Nuclear Operating Business Practice NOBP-LP-4004, "FENOC Regulatory Commitment Management Program," Revision 00, is the primary procedure for the handling of regulatory commitments. This procedure establishes a defined methodology for the assignment, tracking, revision, and closing of commitment tasks. In addition, it provides guidance for determining who is authorized to make regulatory commitments, and who can sign correspondence to the NRC.

The licensee's commitments are tracked in a computer database called FileNet P8. The NRC staff reviewed commitment tracking entries in FileNet P8 and observed the use of FileNet P8 tosearch for commitments. The FileNet P8 system also manages the regulatory commitments of the licensee's other nuclear power plants, Davis-Besse Nuclear Power Station and Beaver Valley Nuclear Power Station.

Nuclear Operating Reference Manual NORM-LP-4004, "FENOC Regulatory Commitments,"

Revision 00, provides supplemental information describing the commitment management tracking system. This manual provides instructions for how to search for commitments within FileNet P8. It also discusses commitment identification, commitment tracking reports, and sorting options. It does not, however, contain instructions for creating, modifying, or closing commitments within FileNet P8.

The NRC staff also reviewed the following FENOC forms related to the Commitment Management Program:

NOBP-LP-4004-01, Revision 00, "Request to Close Commitment Tracking Item."

NOBP-LP-4004-02, Revision 00, "Request to Change Commitment Tracking Item."

NOBP-LP-4004-03, Revision 00, "Regulatory Commitment Change Questionnaire."

NOBP-LP-4004-04, Revision 00, "Commitment Verification."

2.1.2 Audit Results-Implementation of NRC Commitments The attached Audit Summary, Table 1, provides details of the audit and its results.

Overall, the NRC staff concludes that NOBP-LP-4004, Revision 00, NORM-LP-4004, Revision 00, and the associated commitment management forms used in conjunction with the FileNet P8 commitment tracking database constitute an effective program to identify, manage, and close commitments made to the NRC as part of licensing actions and activities.

The NRC staff reviewed the documentation associated with the sampled closed regulatory commitments, and found that the commitments had been closed in a manner that fully satisfied the commitments made to the NRC. At the time of the audit, there were no open commitments to review.

The NRC staff found that the FileNet P8 database is able to provide the necessary information (e.g., summary of the commitment, lead department, responsible individual, due date, closure method and date, and reference documents) to effectively manage regulatory commitments.

Each commitment entry in FileNet P8 contains links to the documents that created, implemented, changed, or closed the commitment.

Although FileNet P8 is an effective tool for managing commitments, the NRC staff found minor inconsistencies in the manner that commitments were closed within the system. NOBP-LP-4004, Section 4.4.5, Part 6 states that when a commitment Closure Form is submitted:

The commitment tracking coordinator ensures the commitment tracking system is updated to designate the status of the regulatory commitment as indicated on the Closure Form and ensures all of the pertinent closure information is referenced and retrievable in the commitment tracking system.

Documents can be attached to FileNet P8 entries and classified as Updates, Closure, Implementing, or Related, among several other options. During the audit, it was noted that closure documents for some commitments were attached with a classification of Updates, while others were attached with a classification of Related. Also, in some cases, the closure letter number and date were listed in the database, while in other cases they were not. Neither NOBP-LP-4004 nor NORM-LP-4004 specifies the manner of referencing or retrieving the closure information. The auditor observed that some of the inconsistencies were due to different practices being followed at each of the three plants in the licensee's fleet. The NRC staff recommendation is to integrate the best practices from each plant to establish a standard process for referencing and retrieving closure documents in FileNet P8 that can be used by everyone who edits, closes, or tracks commitments.

2.2 Verification of the Licensee's Program for Managing 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. Accordingly, the NRC staff compared procedure NOBP-LP-4004 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 reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC.

2.2.1 Audit Results-Managing NRC Commitment Changes The attached Audit Summary, Table 1, also provides details of this portion of the audit and its results.

The NRC staff found that NOBP-LP-4004 follows closely the guidance of NEI 99-04 in regards to managing commitment changes and that the procedure is appropriate. The staff observed that the licensee had generally complete and accurate records, and had documented the sampled commitment changes appropriately using NOBP-LP-4004-02, Revision 00, "Request to Change Commitment Tracking Item," and NOBP-LP-4004-03, Revision 00, "Regulatory Commitment Change Questionnaire." The NRC staff observed that overall the licensee tracking system was effective in documenting the commitment change process, ensuring traceability of commitments, and considering reporting requirements.

Though there were no open commitments to review, the NRC staff did review several maintained commitments, which are commitments that are maintained in implementing documents. NOBP-LP-4004, Section 3.9 states the following:

Commitments designated to be Maintained are to be kept up to date as appropriate and should be either annotated within the implementing document or within the commitment tracking system as associated with the implementing document, which shall be associated with a controlled program or procedure for traceability.

All maintained commitments reviewed were appropriately annotated within the commitment tracking system and implementing documents. NOBP-LP-4004, Section 4.4.4 states:

For closure of regulatory commitments with a status of Maintained, Form NOBP-LP-4004-03, Regulatory Commitment Change Questionnaire must be completed to determine if NRC notification is required and to provide the means required to make this communication.

The NRC staff reviewed maintained commitments that had been closed, and verified that in each case the NRC notification requirements had been reviewed in accordance with Form NOBP-LP-4004-03.

Similar to the inconsistencies found in FileNet P8 entries for closed commitments, there were also some minor inconsistencies noted for maintained commitments. Some commitments that are currently maintained have a Close Date entered in the tracking system. Other maintained commitments had no Close Date entered. Several commitments which changed status from maintained to closed have an incorrect Close Date. Neither NOBP-LP-4004 nor NORM-LP-4004 specifies the manner of documenting maintained commitments within FileNet P8. The NRC staff recommendation is to integrate the best practices from each of the licensee's plants to establish a standard process for managing maintained commitments in FileNet P8 that can be used by everyone who edits, closes, or tracks commitments.

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

Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (i.e., commitments used to ensure safety). Each of the commitments selected for the audit sample were reviewed to determine if any had been misapplied. No misapplied commitments were found.

2.3.1 Review of Safety Evaluation Reports for Licensing Actions since the Last Audit to Determine if They Are Properly Captured as Commitments or Obligations In addition to the commitments selected for the audit sample, all license amendment safety evaluations, exemptions, and relief request safety evaluations that have been issued for a facility since the last audit were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above. No misapplied commitments were found.

3.0 CONCLUSION

The NRC staff concludes, based on this audit, that the licensee has (1) an effective program for managing and implementing regulatory commitments, and (2) an effective program for managing changes to regulatory commitments. The auditor's two recommendations were minor in nature and were discussed with the licensee. No further action is required.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Kathleen Nevins Phil Lashley Principal Contributors: A Dietrich, NRR B. Venkataraman, NRR Date: January 5, 2015

Commitment No(s)./ Descriptions PY-L02553 Support efforts to develop a TSTF traveler to resolve gas accumulation issues; Evaluate traveler's applicability to PNPP; evaluate adopting the traveler TABLE 1 Audit Summary FirstEnergy Nuclear Operating Company (FENOC)

Perry Nuclear Power Plant, Unit 1 Docket No. 50-440 Review FENOC "L-08-315, Nine Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated October 14, 2008]] (ADAMS Accession No. ML082980365) contained three regulatory commitments in response to Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (ADAMS Accession No. ML072910759). The first two regulatory commitments were closed prior to the previous commitment management audit conducted in December 2011.

Commitment 3: After NRC approval of the Traveler, FENOC will evaluate its applicability to PNPP, and evaluate adopting the Traveler to either supplement or replace the current TS requirements.

Auditor's Assessment The Notice of Availability for TSTF-523 was published by the NRC on January 15, 2014 (79 FR 2700). The commitment was closed on July 9, 2014. Perry evaluated Technical Specifications Task Force (TSTF) Traveler 523 in Fleet Licensing Memo 2014-020. The result of the evaluation was that Perry will not presently be incorporating TSTF-523. As stated in the memo, the licensee may reconsider this evaluation pending further understanding of industry implementation issues and clarification of the NRC intentions for follow-up actions.

The commitment was appropriately closed.

Commitment No(s). I Descriptions PY-L-12-128-01 PY-L-12-128-02 PY-L-12-128-04 Provide Requested Information in response to NRC 50.54(f) letter PY -L 283-03 Provide requested information in response to NRC 50.54(f) letter Review FENOC letter dated May 9, 2012 (ADAMS Accession No. ML12130A416) contained three regulatory commitments numbered 1, 2, and 4 in response to NRC's 10 CFR 50.54(f}

letter regarding Near Term Task Force (NTTF)

Recommendations 2.1, 2.3, and 9.3 (ADAMS Accession No. ML12053A340)

Commitment 1: FENOC will provide the requested information for the Communications Assessment (Communications Request

2) and Staffing Assessment (Staffing Requests 3, 4, and 5) by June 11, 2012.

Auditor's Assessment All three commitments have been closed. All requested information was submitted on time.

For Commitment 2, the FENOC letter to the NRC that closed the commitment is attached to the Commitment Tracking Report entry with a document classification of RELATED, and includes the corresponding letter number and date.

For Commitment 1, the letter that closed the commitment is attached with a classification of UPDATES, with the corresponding date but no referenced letter number.

Commitment 2: FENOC will provide the requested information For Commitment 4, the letter that closed the commitment is for the Communications Assessment (Communications Request listed with a classification of UPDATES, with neither a letter 1 and 3) by October 31, 2012.

number nor date listed.

Commitment 4: FENOC will provide the requested information for Phase 2 of the Staffing Assessment (Staffing Request 1, 2, and 6) by 4 months prior to the beginning of refueling outage, spring 2015.

The spring 2015 refueling outage is scheduled to begin on March 9, 2015. Therefore the due date for Commitment 4 was November 9, 2014.

FENOC letter dated November 27, 2012 (ADAMS Accession No. ML13008A029) contained one regulatory commitment numbered Commitment 3 in response to NRC's 10 CFR 50.54(f) letter regarding NTTF Recommendations 2.1, 2.3, and 9.3 (ADAMS Accession No. ML12053A340)

Commitment 3: Submit to the NRC a supplemental report documenting the seismic walkdowns of equipment listed within "Perry Nuclear Power Plant Near-Term Task Force Recommendation 2.3 Seismic Walkdown Report," Table 6-3 within 120 days following completion of the spring 2013 refueling outage.

Auditor Recommendation 1:

Inconsistencies in the way that closure documents are referenced may lead to the documents being difficult to retrieve, contrary to NOBP-LP-4004. Inconsistencies may also result in confusion over the current status of a commitment. Recommend implementing a standard process for closing commitments in the Commitment Tracking Report to ensure that reference documents are retrievable and that the status of each commitment is clear.

The spring 2013 refueling outage was completed on May 16, 2013. Therefore the due date for Commitment 3 was September 13, 2013. The commitment was closed on June 18, 2013. The requested information was submitted on time, in accordance with the commitment.

For Commitment 3, the FENOC letter to NRC that closed the commitment is attached to the Commitment Tracking Report entry with a document classification of UPDATES, with the corresponding date but no referenced letter number.

See Auditor Recommendation 1.

Commitment No(s). I Descriptions PY-L-12-351-01 Add statement to ISEP to state that the number of inspections related to the RI-ISI alternative request cannot be reduced based on the PRA LERF results PY-L-13-156-03 Implement multi-unit/

multi-source dose assessment capability Review FENOC letter dated October 4, 2012 (ADAMS Accession No. ML12279A118) contained one regulatory commitment as part of a response to a Request for Additional Information (RAI)

(Accession No. ML12167A313) for a request for approval for continued use of Perry's risk informed inservice inspection (RI-ISI) program (ADAMS Accession No. ML113180450).

Commitment 1: FENOC will add a statement to the lnservice Examination Plan (ISEP) to state that the number of inspections related to the RI-ISI alternative request cannot be reduced during the interval based on the PRA (Probabilistic Risk Analysis) LERF (Large Early Release Frequency) results from the new model by December 31, 2012.

FENOC letter dated June 25, 2013 (ADAMS Accession No. ML13176A410) contained one regulatory commitment pertaining to implementation of multi-unit/ multi-source dose assessment capability at PNPP.

Commitment 1: Final implementation of multi-unit/multi-source dose assessment capability will occur at PNPP by November 21, 2014.

Auditor's Assessment The commitment changed in status from Open to Maintained on December 27, 2012. The committed change was made to the ISEP Section 2.5, Note 4.

The ISEP is annotated to reference the commitment that implemented the statement. The ISEP is attached to the Commitment Tracking Report entry with a document classification of CLOSURE. The commitment Close Date is left blank, since the commitment has not yet been closed.

The commitment is being appropriately maintained.

The commitment was closed on November 21, 2014. Perry's Meteorological Information and Dose Assessment System (MIDAS) single and multiple accident application dose assessment software was deployed at the Stations Control room and the Emergency Response Facilities on November 21, 2014.

The commitment was appropriately closed.

Commitment No(s). I Descriptions PY-800680 PY-800681 Take actions in response to NRC Generic Letter 89-1 0 Review The Cleveland Electric Illuminating Company letter PY-CEIINRR-1115L dated December 28, 1989 contained regulatory commitments in response to GL 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance" (ADAMS Accession No. ML031150300).

Commitment PY -800680 - item a. of GL 89-10:

Item a. Review and document the design basis for the operation of each MOV. This documentation should include the maximum differential pressure expected during both the opening and closing of the MOV for both normal operations and abnormal events, to the extent that these MOV operations and events are included in the existing approved design basis.

Commitment PY -800681 - items b. and c. of GL 89-1 0:

Item b. Using the results from item a, establish the correct switch settings. This should include establishing a program to review and revise the methods for selecting and setting all switches for each valve operation. One purpose of this letter is to ensure that a program exists for selecting and setting valve operator switches to ensure high reliability of safety-related MOV's.

Item c. Individual MOV switch settings should be changed to those established in response to item b. The MOV should be demonstrated to be operable by testing it at the design-basis differential pressure and/or flow determined in response to item

a. An explanation should be documented for any cases where testing with the design-basis differential pressure or flow cannot practicably be performed.

Auditor's Assessment Both commitments changed status from Maintained to Closed on November 26, 2013.

Documentation of MOV design basis was completed in accordance with PY-800680. It was accepted by the NRC based on the 1996 inspection report 50-440/96005; therefore the commitment is no longer required to be maintained and has been closed.

The correct switch settings were established and the MOV operability was demonstrated in accordance with Commitment PY-800681. The results were accepted by the NRC based on the 1996 inspection report 50-440/96005; therefore the commitment is no longer required to be maintained and has been closed.

In the auditor's review of the commitment tracking report entries, the Close Date was recorded as June 29, 1992 for commitment PY-800680 and March 11, 1997 for commitment PY-800681, though both commitments were in a Maintained status until 2013. The closure documents attached to both entries have a classification of UPDATES, with a date of November 26, 2013, the date that form NOBP-LP-4004-01, "Request to Close Commitment Tracking Item," was completed. According to the commitment tracking coordinator, a Close Date should not be entered until a commitment is officially closed using NOBP-LP-4004-01.

Auditor Recommendation 2:

Entering a Close Date for commitments that have a status of Maintained can lead to confusion over the current status of maintained commitments and the official closure dates of closed commitments. Recommend implementing standard processes for placing commitments into Maintained status and for closing maintained commitments in FileNet P8, to ensure that a Close Date is only entered after a commitment is officially closed using form NOBP-LP-4004-01.

Commitment No(s)./ Descriptions PY-L01157 Change of commitment text for Air Quality Standard for Service Air System (Instrument Air)

PY-L02308 Periodic verification of design basis capability-safety related MOV's Review The Cleveland Electric Illuminating Company letter PY-CEI/NRR-0306L dated August 8, 1985 contained one commitment as part of a response to an RAI regarding a Final Safety Analysis Report (FSAR) amendment concerning maximum allowable particle size for the service air systems.

Original Commitment text: When the system is opened for maintenance, PNPP Procedure PAP-0204 requires a test blow followed by an air quality test for 40 micron particle size downstream of the repair using an air particle counter.

Changed Commitment text: When the service air (instrument air) system is opened (except for work done upstream of the air after filters or downstream of the J-manifold) a test blow followed by a verification of air quality using an air particle counter is required. The acceptance criterion is no particles over 40 microns.

Centerior Energy Letter, PY-CEI/NRR-2114L dated November 18, 1996 contained two regulatory commitments in response to GL 96-05, "Periodic Verification of Design-Basis Capability of Safety Related Motor-Operated Valves" (ADAMS Accession No. ML031110010). Commitment 2 was closed in 1997.

Commitment 1: The effectiveness of PNPP's current program to verify, on a periodic basis, that safety related MOV's continue to be capable of performing their safety functions within the current licensing basis of the facility, will be ensured. This will be accomplished by reviewing the PNPP periodic verification program developed in response to GL 89-10, "Safety-Related Motor-Operated Valve Testing and Surveillance," to determine whether any periodic verification program changes are appropriate in light of the information in GL 96-05. This program will be evaluated and modified as appropriate, to ensure that changes in performance resulting from degradation (e.g., age-related) are properly identified and accounted for Auditor's Assessment The commitment status is Maintained with a change in text made on December 26, 2012.

The commitment tracking report entry shows a Maintained status with a Close Date of November 7, 1989. According to the commitment tracking coordinator, a Close Date should not be entered until a commitment is officially closed using NOBP-LP-4004-01.

See Auditor Recommendation 2.

The commitment status is Maintained with a change in the commitment made on April 26, 2012.

The commitment change was to allow the test interval for the drywell backup purge containment isolation MOV, 1 M51 F0090, to exceed the 1 0-year frequency so that it could be tested during the next plant refuel outage. This commitment revision documented the one-time exception for the containment isolation valve to exceed the 10-year frequency.

In the commitment tracking report, the commitment Close Date is listed as December 21, 1998, which is not referenced anywhere else. According to the commitment tracking coordinator, a Close Date should not be entered until a commitment is officially closed using NOBP-LP-4004-01. The commitment change documents are attached to the FileNet P8 entry with a classification of UPDATES, though no date is provided.

See Auditor Recommendation 2.

There is no need for the licensee to respond to this letter. The NRC staff appreciates the resources that were made available by your staff during the audit. If you have any questions, please contact me at (301) 415-2846.

Docket No. 50-440

Enclosure:

Audit Report cc w/encl: Distribution via Listserv DISTRIBUTION:

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• ML14353A367 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/PM NAME BVenkataraman ADietrich DATE 12/30/20/14 12/30/2014 Sincerely, IRA/

Allison W. Dietrich, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation NRR/LPL3-2/PM NRR/LPL3-1/LA NRR/LPL3-2/BC EBrown MHenderson TT ate (DPelton for) 1/05/2015 12/29/2014 01/05/2015 OFFICIAL RECORD COPY