ML15057A190

Audit of the Licensees Management of Regulatory Commitments, Regulatory Commitments Changes, and Appropriateness of Application of the Regulatory Commitments

ML15057A190
Person / Time
Site:	Millstone
Issue date:	03/16/2015
From:	Thadani M Plant Licensing Branch 1
To:	Heacock D Dominion Nuclear Connecticut
Thadani M
References
TAC MF5093, TAC MF5094
Download: ML15057A190 (31)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David A Heacock President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 March 16, 2015

SUBJECT:

MILLSTONE POWER STATION, UNITS 2 AND 3 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS, REGULATORY COMMITMENTS CHANGES, AND APPROPRIATENESS OF APPLICATION OF THE REGULATORY COMMITMENTS (TAC NOS. MF5093 AND MF5094)

Dear Mr. Heacock:

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the Nuclear Regulatory Commission (NRC) informed the 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 the 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 the licensees* regulatory commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04 and those regulatory commitments are being effectively implemented.

On December 2 and 3, 2014, the NRC staff performed an audit of the licensee's regulatory commitment management program at Millstone Power Station, Units 2 and 3. The NRC staff selected a sample of the licensee's records of regulatory commitments to perform the audit.

The selected sample was used to review the licensee's management of the regulatory commitments, and verification that the regulatory commitments are being appropriately applied to ensure that they did not constitute obligations under the NRC's regulatory requirements.

During the audit the licensee's staff informed the NRC staff that during the current triennial audit period there were no changes made to the regulatory commitments. Therefore the NRC staff' performed the programmatic review of the regulatory commitment change program.

Based on the audit of a selected sample of the reguiatory comr.iitments, and the licensee's programs and procedures for managing the regu1atory commitments, the NRC staff concludes that the licensee has implemented its regulatory commitments management program, and regulatory commitments change management program in accc;rdance with the industry guidance in NEI 99-04. The NRC staff's rev,ew of the sample confirmed that the licensee is applying the regulatory commitments in an appropriate manner to ensure that the regulatory commitments did not involve any obligations under the NRC's regulatory framework. The

details of the audit, including the NRC staff observations and recommendations, are set forth in the enclosed audit report.

The licensee's staff supporting the NRC staff's audit included William D. Bartron, William E.

Brown, Ms. Marylou L. Calderone, and Mr. David B. Blakeney.

The NRC staff appreciates the considerable assistance provided by the licensee's staff to facilitate timely completion of the NRC staff's audit.

Please contact me at (301) 415-1476 or email Mohan.Thadani@nrc.gov, if you have any questions on this issue.

Docket Nos. 50-336 and 50-423

Enclosure:

Audit Report cc w/encl: Distribution via Listserv Sincerely,

~C/h~~

Mohan C. Thadani, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS MANAGEMENT PROGRAMS DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION, UNIT NOS. 2 AND 3 DOCKET NOS. 50-336 AND 50-423

1.0 INTRODUCTION

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the Nuclear Regulatory Commission (NRC) informed the 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 the 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 those regulatory commitments are being effectively implemented.

The NEl-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 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, orders, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS On December 2 and 3, 2014, the NRC staff performed its triennial audit of the Millstone Power Station, Units 2 and 3 (MPS) regulatory commitment management program, regulatory commitments change program, and verification that the regulatory commitments are being appropriately applied at MPS. The NRC staff selected the sample of regulatory commitments summarized in the attached table. The sample of regulatory commitments audited includes the triennial period from December 2011 through December 2014:

Enclosure 2.1 Verification of Licensee's Implementation of Regulatory Commitments The MPS is a part of the Dominion Nuclear Connecticut, Inc. (Dominion) fleet. As a result of the consolidation of MPS in the Dominion fleet corporate structure, the MPS's commitment management activities were folded into Dominion's template of the management of regulatory commitments.

2.1.1 Audit Scope The NRC staff focused the audit on a sample of regulatory commitments. The sample was selected from information obtained from the licensee prior to the audit visit and consisted of regulatory commitments 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.). The sample was representative of the licensee's regulatory commitments database. The sample is contained in the Attachment to this report.

The audit excluded the following types of commitments that were part of licensee's internal 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).

(3)

Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications (TSs), and Updated Final Safety Analysis Reports.

The selected sample of regulatory commitments is provided in the Table contained in the attachment. The table gives information on the regulatory commitments tracking program. It displays licensee's numbers for letters in which the licensee made the regulatory commitments in writing (column 1 ), description of the regulatory commitments made to the NRC (column 2),

regulatory commitment record number (RCR) in column 3, the licensee's control number (LC) in column 4, licensee's action number (LA) in column 5, central regulatory system (CRS) type as licensing action type (LCR) in column 6, notes in column 7, and the status of the regulatory commitment (whether closed, etc.) in column 8. The licensee stated that there were no regulatory commitment changes reported in the triennial period of this audit. The commitment closure status is indicated in column 8.

2.1.2 Audit Results The NRC staff reviewed the licensee documents against the sample commitments and concluded that the licensee's administrative procedures for managing regulatory commitments generally implement the industry guidance in NEl-99-04 guidelines. The documentation provided by the licensee during the audit confirmed the NRC staff's conclusion that the licensee's regulatory commitments are being tracked effectively.

2.2 Verification of the Licensee's Regulatory Commitments Change Management The licensee stated that there were no changes made to the regulatory commitments in the sample of this triennial period. The NRC staff's primary focus of this part of the audit was to confirm that the regulatory commitments change procedures were consistent with the industry guidance contained in NEI 99-04.

2.2.1 Audit Results The NRC staff's audit of the commitment change procedures verified that the licensee has provision which follows the industry guidance to inform the NRC of any changes made to the regulatory commitments as appropriate.

2.3 Verification of Appropriate Application of Regulatory Commitments.

The NRC staff reviewed the licensee's regulatory commitments in the table contained in the attachment to determine if any of the audited regulatory commitments constituted obligations under the NRC's regulatory requirements. Based on this review of the licensee provided documents, the NRC staff concludes that the licensee is not misapplying the regulatory commitments.

3.0 CONCLUSION

Based on the above, the NRC staff concludes that: (1) MPS is implementing and tracking the regulatory commitments consistent with the NRC accepted industry guidance contained in NEI 99-04, (2) MSP has an effective program to manage regulatory commitment changes, and (3) the NRC staff did not find any misapplied regulatory commitments in the sample reviewed during the audit.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT The Licensee's personnel contacted for this audit included William D. Bartron, William E. Brown, Marylou L. Calderone, and David B. Blakeney.

ATTACHMENT Millstone Power Station Regulatory Commitments Sample for the period From December 2011 1 to December 2014

Letter Number 11-596 12-036 pg.6 Commitment Dominion Nuclear Connecticut, Inc. (DNC) will confirm that Westinghouse has provided additional confirmatory data associated with lead test assembly programs at other facilities, as available, prior to the use of Optimized ZIRLOTM in a reload cycle.

DNC commits to revise the MPS3 ISi program to include the inspection requirements of the 2004 Edition (no Addenda) of ASME BPV Code,Section XI, Article IWF-5300(c) for integral and non-integral snubber attachments by April 1, 2013.

RCR Number 43006 43014 Millstone Power Station Commitment Letter Log LC Number LC000967 LC000944 LA Number LA003791 LA003684 CRS LA Type as LCR Yes Yes Notes Status Closed

Letter Number 12-205A 12-205A 12-205A pg. 7 Commitment A pre-planned response will be developed and personnel will be appropriately instructed to ensure the ERO response following a defined "major event" is consistent with provided expectations.

Pursuant to this process, the ERO will report directly to the station or to pre-determined staQinQ areas.

Satellite phone will be used to activate the ERO callout process. Once activated, the system initiates pager notification and automatic phone calls to ERO personnel.

This method is a defense-in-depth adjunct to Preplanned Response. Local radio station Emergency Alert System (EAS) broadcasts will be used to instruct ERO members in the event of a major event or disaster, when normal means of communication are not available. It will be designed to provide information to enable augmented ERO personnel to respond to the RCR Number 43046 43046 43046 Millstone Power Station Commitment Letter Log LC Number LC000966 LC000966 LC000966 LA Number LA003779 LA003780 LA003781 CRS LA Type as LCR Yes Yes Yes Notes Status This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

Letter Number 12-205A pg.8 Commitment event more effectively. ERO members outside the 25-mile zone, or those within the 25-mile zone with car radios or other battery-powered radios, would be able to receive these broadcasts.

There are two roadways into the Millstone Power Station, both of which intersect with Route 156 (Rope Ferry Road), which crosses the Niantic Bay by bridge approximately 0.5 miles west of its intersection with the main access road.

To the east and north, Route 156 connects to a network of roadways from which access to Interstate 95 is available.

The main access road crosses over a commercial rail corridor between Route 156 and Millstone Power Station.

The secondary access road, which is normally blocked by vehicle barriers, is via Gardiners Wood RCR Number 43046 Millstone Power Station Commitment Letter Log LC Number LC000966 LA Number LA003782 CRS LA Type as LCR Yes Notes Status This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

Letter Number 12-205A pg.9 Commitment Road and Millstone Road (Millstone Road No.1 ).

Gardiner's Wood Road intersects with Route 156 approximately 0.5 miles east of the main access road.

An agreement exists with the State of Connecticut to permit passage of Dominion Nuclear Connecticut, Inc.

(DNC) personnel if roads are closed, but safe passage is possible.

Access to Millstone Power Station can be provided from staging areas via helicopters arranged by DNC or the State of Connecticut.

RCR Number 43046 Millstone Power Station Commitment Letter Log LC Number LC000966 LA Number LA003783 CRS LA Type as LCR Yes Notes Status This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

Letter Number 12-205A 12-205A 12-205A 12-205A pg. 10 Commitment Millstone Power Station can also be accessed from the Long Island Sound. DNC will evaluate the use of boats for transport of personnel.

Note: This means of transport may not be an option during a severe storm.

Develop procedure for ERG notification under degraded communications capabilities Develop procedure for implementing control of site access following large scale natural event.

Develop and implement training for ERG notification under degraded communications capabilities.

This assignment can be given to training per D. Smith and Torey Matthesss.

RCR Number 43046 43046 43046 43046 Millstone Power Station Commitment Letter Log LC Number LC000966 LC000966 LC000966 LC000966 LA Number LA003784 LA003785 LA003786 LA003787 CRS LA Type as LCR Yes Yes Yes Yes Notes Status This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are

Letter Number 12-205A 12-205A 12-205A pg. 11 Commitment Develop and implement training for control of site access following large scale natural event. This assignment can be given to training per D. Smith and Torey Matthesss Evaluate the use of boats for transport of personnel.

Purchase/Contract for two (2) portable diesel generators with AC Purchase Order power cables to power temporary lighting and support emergency issued 3/29/2012 response and communications functions.

This assignment should go to BOB Project, Dave Bucheit, Bill Webster and Diane Aitken RCR Number 43046 43046 43046 Millstone Power Station Commitment Letter Log LC Number LC000966 LC000966 LC000966 LA Number LA003788 LA003789 LA003805 CRS LA Type as LCR Yes Yes Yes Notes Status complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

Letter Number 12-205A 12-205A pg. 12 Commitment Purchase/Contract for six (6)

Iridium Satellite Phones, Model 9575 Purchase Order Extreme Satellite Phone (or equivalent) - Emergency Responder issued 3/29/2012 Package with Solar Panel to provide communications capability in for delivery the event of unavailability of cellular and land-line phones to between Operations and the Emergency Response Organization (ERO)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued the referenced letter. of the letter contains specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs. In accordance with 1 O CFR50.54, "Conditions of licenses," paragraph (f),

addressees were requested to submit a written response to the information requests. The letter also specified due dates for RCR Number 43046 43046 Millstone Power Station Commitment Letter Log LC Number LC000966 LC000966 LA Number LA003806 LA004218 CRS LA Type as LCR Yes Yes Notes Status This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

This one RCR Closed documented the ACTIONS agreed to in Letter no. 12-205A, Enclosure 1 Table. All ACTIONS are complete.

Letter Number 12-205G 12-205G 12-205H pg. 13 Commitment written responses.

In accordance with the referenced letter, on May 9, 2012, Dominion Nuclear Connecticut, Inc. (DNC) submitted an alternative course of action for providing the requested information.

The alternative course of action included revised information due dates and the basis for those dates.

Perform walkdown of the Security Electrical Cable Pull Box PBG1 prior to July 1, 2013 Perform walkdown of the Security Electrical Cable Pull Box located in the West Condenser Pit of the MPS2 turbine building prior to July 1, 2013.

Seismic walkdowns that could not be completed due to inaccessibility will be completed as indicated in Table 3-1 and Table 3-2 and a sup-plemental submittal will be provided to the NRC for MPS2 and MPS3 by August 30, 2014.

RCR Number 43016 43017 43018 Millstone Power Station Commitment Letter Log LC Number LC001057 LC001057 LC001046 LA Number LA004166 LA004166 LA004118 CRS LA Type as LCR Yes Yes Yes Notes Status LA004166 covers Closed both commitments as item 1 and item 2 of the LA.

LA004166 covers Closed both commitments as item 1 and item 2 of the LA.

Closed

Letter Number 12-337 12-745 was cancelled and reissued as No.14-107 12-745 was cancelled and reissued as No.14-107 12-745 was cancelled and reissued as No.14-107 pg. 14 Commitment Plans to periodically verify the design-basis capability of JOG Program Class O MOVs will be completed by September 25, 2012 and available at the stations for inspection.

ONG will implement administrative controls to ensure that activities that degrade the availability of the RCS pressure relief system, the auxiliary feedwater system, AMSAC, or turbine trip should not be scheduled when a logic train or an RTB train is inoperable for maintenance.

ONG will implement administrative controls to ensure that one complete EGGS train that can be actuated automatically must be maintained when a logic train is inoperable for maintenance.

ONG will implement administrative controls to ensure that activities that cause RTS and ESFAS master relays or slave relays in the available train to be unavailable, and activities RCR Number 43015 43019 43020 43021 Millstone Power Station Commitment Letter Log LC Number LC000961 LC001261 LC001261 LC001261 LA Number LA003738 LA005393 LA005396 LA005397 CRS LA Type as LCR Yes Yes Yes Yes Notes Status Closed Reissued as 14-Open 107.

Reissued as 14-Open 107.

Reissued as 14-Open 107.

Letter Number 12-745 was cancelled and reissued as No.14-107 pg. 15 Commitment that cause RTS and ESFAS analog channels to be unavailable, should not be scheduled when a logic train or an RTB train is inoperable for maintenance, with the exception of ESFAS Functions 2.c and 3.b.(3).

DNC will implement administrative controls to ensure that activities that result in the inoperability of electrical systems (e.g., AC and DC power) and cooling systems (e.g., service water and component cooling water) that support the RCS pressure relief system, the AFW system, AMSAC, turbine trip, one complete train of ECCS, and the available reactor trip and ESF AS actuation functions should not be scheduled when a logic train or an RTB train is inoperable for maintenance. That is, one complete train of a function that supports a complete train of a function noted above must be available.

RCR Number 43022 Millstone Power Station Commitment Letter Log LC Number LC001261 LA Number LA005399 CRS LA Type as LCR Yes Notes Status Reissued as 14-Open 107.

Letter Number 13-227 13-227 13-227 13-227 pg. 16 Commitment Administrative controls will be established for cleaning of the RBCCW heat exchangers at a 3-month interval.

Administrative controls will be established for cleaning of the switchgear room coolers, X181NB, at an 18-month interval Administrative controls will be established to address the following: For service water temperatures above 75°F, it may be necessary to also open the RBCCW winter temperature control valves (2-SW-245, 2-SW-246, and 2-SW-247) to maximize flow to the RBCCW heat exchangers to suooort normal operation For the RBCCW system, a RBCCW supply temperature of 85°F in Modes 1, 2 and 3 will be included in the MPS2 FSAR and operating procedures as a design requirement of the RBCCW system. MPS2 operating procedures will be modified to maximize RBCCW flow and minimize RBCCW heat RCR Number 43023 43024 43025 43026 Millstone Power Station Commitment Letter Log LC Number LC001131 LC001131 LC001131 LC001131 LA Number LA004683 LA004684 LA004685 LA004686 CRS LA Type as LCR Yes Yes Yes Yes Notes Status Closed Closed Closed Closed

Letter Number 13-227 13-227 13-227 pg. 17 Commitment loads, as appropriate, whenever SW inlet temperature exceeds 75°F.

For pumps tested in the In-Service Testing (IST) program, the IST acceptance criteria for the SW pumps will be revised to reflect the updated SW maximum flow.

For Generic Letter (GL) 89-13, the RBCCW heat exchanger (X-18A/8/C) surveillance procedures will be revised to increase the differential pressure surveillance frequency to weekly from July through September For Generic Letter (GL) 89-13, cleaning and inspection schedules for the RBCCW heat exchangers (X-18A/B/C) and the emergency diesel generator heat exchangers (X-83A/B, X-53A/B, X-45A/B) will be altered such that those heat exchangers are cleaned annually prior to each summer. Additionally, if necessary, the RBCCW cleaning frequency may increase based on observed RCR Number 43027 43028 43029 Millstone Power Station Commitment Letter Log LC Number LC001131 LC001131 LC001131 LA Number LA004687 LA004688 LA004689 CRS LA Type as LCR Yes Yes Yes Notes Status Closed Closed Closed

Letter Number 13-227 13-227 pg. 18 Commitment RBCCW outlet temperatures and DP surveillance results For the MPS2 Final Safety Analysis Report, the following sections will be updated to reflect the change in ultimate heat sink (UHS) temperature:

Section 1.2.10.3, RBCCW System Section 9.4.3.1, Normal Operation Section 9.4.4.3, Shutdown Section 9.7.2.1.2, Design Criteria Section 14.8.2.2.3, Input and Assumptions For NUREG-1432, Standard Technical Specifications for Combustion Engineering Plants considerations, if all of the installed instrument-tation at the inlet to the RBCCW heat exchangers are out of service; alternative instruments that measure SW supply side temperature will be used. In this case, an appropriate instrument uncertainty will be subtracted from the acceptance criteria.

This guidance will be incoroorated into the RCR Number 43030 43031 Millstone Power Station Commitment Letter Log LC Number LC001131 LC001131 LA Number LA004690 LA004691 CRS LA Type as LCR Yes Yes Notes Status Closed Closed

Letter Number 13-228 13-228 pg. 19 Commitment appropriate MPS2 surveillance procedures.

Section 5.3.2.3, control building air conditioning water chillers:

Revisions to the required flow analyses for the HVK chillers have credited availability of the HVK booster pumps for some fire scenarios. The HVK booster pumps will be added to the list of equipment credited for Fire Protection I Branch Technical (BTP) 9.5-1 Compliance Report and the program will be revised accordingly.

Section 5.3.2.6, MCC & rod control area ventilation units:

The cleaning frequency of the MCC and Rod Control Area Air Conditioning heat exchangers can remain at an annual frequency, as long as cleaning occurs within four (4) months of UHS temperature excursions above 75°F. Revised HX surveillance curves will be implemented coupled with the above specified cleaning time frame to ensure RCR Number 43032 43033 Millstone Power Station Commitment Letter Log LC Number LC001134 LC001134 LA Number LA004694 LA004695 CRS LA Type as LCR Yes Yes Notes Status Closed Closed

Letter Number 13-228 13-228 pg.20 Commitment credited heat removal is retained at the increased UHS temperature Section 5.3.2.11, reactor plant component cooling water system heat exchangers:

The affected piping, supports, and equipment nozzles have been analyzed for temperatures exceeding these limits. Therefore, the operating procedure guidance will be revised to address the higher allowable temperature during normal plant cooldowns.

Section 5.4.1, service water system operating condition evaluation, temperature conditions:

The SW and RPCCW Systems piping, supports, and equipment nozzles have been evaluated for the 5°F UHS temperature increase.

The evaluation utilized quantitative scaling criteria to verify that the piping, supports, and nozzles are acceptable for the increased thermal expansion stress ranae and resulting suooort RCR Number 43034 43035 Millstone Power Station Commitment Letter Log LC Number LC001134 LC001134 LA Number LA004696 LA004697 CRS LA Type as LCR Yes Yes Notes Status Closed Closed

Letter Number 13-228 13-228 pg.21 Commitment and nozzle loadings. The affected calculations of record will be revised to reflect the temperature changes prior to the implementation of the requested License Amendment Request Section 5.5.1, RPCCW temperature conditions -

normal cooldown with instrument air available I not available:

The assessment concluded that the 5°F increase will not result in exceeding any design acceptance criteria for the affected piping, supports, or equipment nozzles. This increase in allowable temperature conditions will be addressed by revising normal cooldown procedures to accommodate the higher RPCCW supply temperature.

Section 5.6, GL 89-13 thermal performance test and program impacts:

New limits will be established on the allowable microfouling of the MCC and Rod Control Area NC HXs.

RCR Number 43036 43037 Millstone Power Station Commitment Letter Log LC Number LC001134 LC001134 LA Number LA004698 LA004699 CRS LA Type as LCR Yes Yes Notes Status Closed Closed

Letter Number 13-228 13-228 13-228 pg.22 Commitment The GL 89-13 Program will be revised to provide new HVR heat exchanger cleaning requirements and revised heat exchanger pressure drop and flow surveillance limits as described in section 5.7.

Section 5.15, motor operated valve program impact:

For the SW System MOVs and the RPCCW System MOVs, small changes to fluid temperature and flow rates will require revision to the system and functional calculations for the MOVs in these systems.

Section 5.16, air operated valve (AOV) program impact:

The system level design basis review calculation for the SW AOVs which documents the bounding operating scenarios for the valves and the system alignments and conditions (e.g., pressure, temperature, flow rate) requires revision.

Section 5.18, hazards I internal flooding impact:

The affected calculations of record will be revised to RCR Number 43038 43039 43040 Millstone Power Station Commitment Letter Log LC Number LC001134 LC001134 LC001134 LA Number LA004700 LA004701 LA004702 CRS LA Type as LCR Yes Yes Yes Notes Status Closed Closed Closed

Letter Number 13-228 13-228 13-228 pg.23 Commitment reflect the line pressure changes prior to the implementation of the requested License Amendment Request.

Section 5.19, the in service testing program (IST) impact:

Flow rates shown in FSAR Table 9.2-1 and the implementing !ST program calculation will be revised to reflect these chanaes.

Section 5.19, the in service testing program (IST) impact:

The IST implementing program calculations will be revised to specify that the comprehensive flow tests will be performed within 20 percent of calculated minimum reauired flows.

Section 5.19, the in service testing program (IST) impact: The change to the UHS temperature does have an impact on the minimum allowable IST pump curve for the MCC and Rod Control Area Air Conditioning Booster Pumps (3SWP*P3A/B). The affected RCR Number 43041 43042 43043 Millstone Power Station Commitment Letter Log LC Number LC001134 LC001134 LC001134 LA Number LA004703 LA004704 LA004705 CRS LA Type as LCR Yes Yes Yes Notes Status Closed Closed Closed

Letter Number 13-228 13-233 pg.24 Commitment IST program implementation documents will be revised to incorporate these chanqes.

Section 5.2, Service water system flow analysis:

Note that performance of both HVR booster pumps were determined to not meet the assumptions of the analysis. These have been entered into the corrective action program (CR513088 and CR514029) and will be corrected prior to implementation of the NRC approved license amendment reauest At the time the Pressurized Water Reactor Owner's Group (PWROG) establishes new in-vessel acceptance criteria, DNC will develop a plan for demonstrating compliance with the PWROG program limits and communicate that plan to the NRC.

RCR Number 43044 43045 Millstone Power Station Commitment Letter Log LC Number LC001134 LC001141 LA Number LA004693 LA004745 CRS LA Type as LCR Yes Yes Notes Status Closed Open

Letter Number 13-623 14-114 pg.25 Commitment DNC will complete a modification that will correct the degraded closing capability of the MPS3 main feedwater isolation valves prior to the restart from refuelinq out 3R16.

Commitment 1 from MPS2 RR-04-20 (DNC Letter 14-114)

Submit a Preliminary Report with Evaluation Results Described in Paragraphs g{2) and g(3) of Code Case N-504-4 Prior to entry into Mode 4 following the completion of the weld overlays, a preliminary report shall be submitted with results of evaluations that are described in Paragraphs g(2) and g(3) of Code Case N-504-4, which requires the following information:

• evaluations of residual stresses and flaw growth of the repaired welds.

• effects of anv chanqes in RCR Number 43047 43048 Millstone Power Station Commitment Letter Log LC Number LC001205 LC001259 LA Number LA005149 LA005365 CRS LA Type as LCR Yes Yes Notes Status Open Open

Letter Number 14-114 pg.26 Commitment applied loads as a result of weld shrinkage from the entire overlay on other items in the piping system

• analysis to confirm that the requirements of sub articles NB-3200 and NB-3600 of the ASME Code, Section Ill are satisfied. The analysis includes the crack growth calculations to demonstrate that crack growth in the weld overlay or base metal is acceptable and residual stress distribution in the weld overlay and original weld demonstrate favorable stress distribution.

Please note that the due date for this assignment may need to be adjusted based on the actual Mode 4 date for2R23.

Commitment 2 from MPS2 RR-04-20 (DNC Letter 14-114):

Submit Information to NRC After Final UT Examination of FSWOL Installations RCR Number 43049 Millstone Power Station Commitment Letter Log LC Number LC001259 LA Number LA005366 CRS LA Type as LCR Yes Notes Status Open

Letter Number 14-114 pg.27 Commitment The following information will be submitted to the NRC within 14 days of completion of the final ultrasonic examination of the FSWOL installations:

• a listing of indications detected

• the disposition of the indications using the standards of ASME Code Section XI, IWB-3514-2 and/or IWB-3514-3 criteria and, if possible, the type and nature of the indications

• a discussion of any repairs to the weld overlay material and/or base metal and the reason for the repairs Commitment 3 from MPS2 RR-04-20 (DNC Letter 14-114):

Submit Final Report with Evaluation Results Described in Paragraphs g(2) and g(3) of Code Case N-504-4 A final report shall be RCR Number 43050 Millstone Power Station Commitment Letter Log LC Number LC001259 LA Number LA005367 CRS LA Type as LCR Yes Notes Status Open

Letter Number pg.28 Commitment submitted with results of evaluations that are described in Paragraphs g(2) and g(3) of Code Case N-504-4, which requires the following information:

• evaluations of residual stresses and flaw growth of the repaired welds.

• effects of any changes in applied loads as a result of weld shrinkage from the entire overlay on other items in the piping system

• analysis to confirm that the requirements of sub articles NB-3200 and NB-3600 of the ASME Code, Section Ill are satisfied. The analysis includes the crack growth calculations to demonstrate that crack growth in the weld overlay or base metal is acceptable and residual stress distribution in the weld overlay and original weld demonstrate favorable stress distribution.

RCR Number Millstone Power Station Commitment Letter Log LC Number LA Number CRS LA Type as LCR Notes Status

Letter Number 14-337 14-337 Commitment By December 17, 2014, DNC will apply other methodologies, such as ground penetrating radar assessment, around the perimeter of the protected area to validate that no additional unattended openings exist.

By December 31, 2014, DNC will create a controlled station drawing documenting all known underground penetrations of the protected area, including the results related to the use of other methodologies such as ground penetrating radar assessment.

RCR Number 43068 43069 Millstone Power Station Commitment Letter Log LC Number LC001341 LC001341 LA Number LA005752 LA005753 CRS LA Type as LCR Yes Yes Notes Status Open Open

• CR452814 Identified commitments that were not entered into the Commitment Tracking System and were identified by the NRC Audit of Regulatory Commitments performed November 15 and 16, 2011 and documented in report dated December 28, 2011. Corrective Actions documented in CR452814 included entering identified commitments into the RCD for historical purposes and to document their completion.

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ML15057A190 OFFICE LPLl-1/PM LPLl-1/LA LPLl-1/BC NAME MThadani KGoldstein BBeasley DATE 3/03/2015 03/02/2015 3/16/2015