ML15139A301

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Audit of the Licensees Management of Regulatory Commitments
ML15139A301
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 05/27/2015
From: Jennivine Rankin
Plant Licensing Branch III
To: Fessler P
DTE Electric Company
Rankin J
References
TAC MF5553
Download: ML15139A301 (18)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 27, 2015 Mr. Paul Fessler, Senior VP and Chief Nuclear Officer DTE Electric Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, Ml 48166

SUBJECT:

FERMI 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULA TORY COMMITMENTS (TAC NO. MF5553)

Dear Mr. Fessler:

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 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and if regulatory commitments are being effectively implemented.

An audit of the Fermi 2 commitment management program was performed at the plant site on May 12 - 14, 2015. The NRC staff concluded that, based on the audit, Fermi 2 has implemented NRC commitments on a timely basis, and has implemented an effective program for managing commitment changes. Details of the audit are set forth in the enclosed audit report.

Please feel free to contact me at (301) 415-1530 if you have any additional questions or concerns.

Docket No. 50-341

Enclosure:

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

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Jennivlne K. Rankin, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS DTE ELECTRIC COMPANY FERMI 2 DOCKET NO. 50-341

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 if regulatory commitments are being effectively implemented. An audit of the Fermi 2 commitment management program was performed at the plant site during May 12 - 14, 2015. The audit reviewed commitments made, changed, or closed since the previous audit conducted during the period July 31, 2012 through August 3, 2012.

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.

Enclosure 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 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 (TSs).

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

2.1.2 Audit Results - Implementation of NRC Commitments The licensee has implemented procedure MLS10, Revision 13, "Regulatory Action and Commitment Tracking," which describes the methods for managing NRC commitments in the Regulatory Action and Commitment Tracking System (RACTS) database at Fermi 2. The NRC staff compared the guidance in MLS10, Revision 13 to the guidance in NEI 99-04. As a result of the comparison, the NRC staff found that the Fermi 2 procedure was generally consistent with the NEI guidance for identifying, managing, and closing commitments.

The audit verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

The documents furnished by the licensee during the audit included RACTS summary sheets providing the status of the commitments and appropriate implementing documentation, as needed (i.e. procedure revisions, completed work orders, memorandums, commitment change evaluation forms). The NRC staff reviewed the documents and summarized the selected commitments in the attached Audit Summary.

The NRC audit confirmed that the licensee has documented its implementation of regulatory commitments made to the NRC staff as part of past licensing actions. The NRC staff notes that there is an inconsistency in the time that regulatory commitments are entered into the commitment management program. MLS10, Revision 13, indicates that commitments are entered into the program upon receipt of the NRC correspondence (i.e., NRC safety evaluations (SEs)); however, the NRC staff noted that some regulatory commitments are entered into the system prior to receiving the NRC SE and some are entered into the system afterwards. The NRC did not identify any regulatory commitments that were not satisfied or incorporated into its commitment management program for implementation (after receipt of an NRC SE). The NRC discussed this inconsistency with the licensee.

Licensee personnel were able to demonstrate effective use of the commitment management database and provided status tracking to the applicable implementation documents. The NRC staff found that generally, the selected commitments in the audit sample were effectively implemented. Using the RACTS as a starting point, the NRC staff sought to determine that commitments were implemented in documents such as plant procedures, or in appropriate engineering packages. In addition, the NRC audit confirmed that the process to close out commitments and provide sufficient justification for closure was adequate. The attached Audit Summary provides details of-the audit and its results.

Based on the above, the NRC staff concludes that the licensee has implemented the regulatory commitments management program effectively in accordance with LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC," and consistent with NEI 99-04.

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. 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 Fermi 2 is contained in DTE Electric Company's MLS 10, Revision 13. The audit reviewed a sample of commitment changes that included changes that were or will be reported to the NRC.

2.2.1 Audit Results - Managing NRC Commitment Changes The audit sample included one commitment that was expanded and two commitments that were classified as "deleted." At Fermi 2, commitments can be deleted if the commitment was incorrectly classified as on ongoing commitment; or if the committed action is met and the subject of the commitment is not being altered and the commitment is greater than 2 years old (i.e., Sunset Deleted). The attached Audit Summary provides details of this portion of the audit and its results.

Based on the review of the reports provided by the licensee as described above, the accompanying change review and tracking forms provided during the audit, the NRC concludes that the licensee has established effective administrative controls for managing NRC commitment changes.

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 identified within the audit scope.

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. There were no misapplied commitments found in the NRC staff evaluations for amendments, exemptions, relief requests, or other licensing tasks since the last commitment management audit.

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.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Jason Haas Sam Hassoun Principal Contributors: J. Rankin, K. Green Date of issuance: May 27, 2015

Attachment:

Summary of Audit Results

RACTS No.

Description of Commitment 20303 DTE will follow the guidance established in Section 11 of NUMARC 93-01,"lndustry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" Nuclear Management and Resource Council, Revision 3, July 2000.

20304 DTE will follow the guidance established in TSTF-IG 02, Revision, "Implementation Guidance for TSTF-423, Revision 1, Technical Specifications End States, NE DC-32988-A. II Audit Summary DTE Electric Company Fermi 2 Docket No. 50-341 Documents Reviewed Letter NRC-13-0001, dated January 11, 2013 (ADAMS Accession No. ML13014A125)

MMR02, Revision 4, "Maintenance Rule Program Description."

Letter NRC-13-0001, dated January 11, 2013 (ADAMS Accession No. ML13014A125) 24.000.01, Revision 70, "Situational Surveillances/LCO Action Tracking."

MMR12, Revision 16, "Equipment Out of Service Risk Management."

22.000.04, Revision 73, "Plant Shutdown From 25% Power."

Status Auditor's Assessment Ongoing-Closed. Verified that Section 1.2 of Closed MMR02, Rev. 4 is consistent with NUMARC 93-01, Section 11.

Due Date:

3/18/14 Completed:

3/3/14 I

Ongoing-Closed. Verified procedures were updated Closed to reflect Amendment 194 mode 3/end states. MMR12, Revision 16 revised Due Date:

appropriately and annotated with RACTS 3/18/14 number to indicate changes to the procedure correlate with a regulatory Completed:

commitment.

3/3/14 Attachment

2 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 20305 Limitations regarding Letter NRC-13-0004, dated February Ongoing-Closed. The startup from the RF16 outage operation with an inoperable 7, 2013 (ADAMS Accession No.

Closed was on 4/5/14. Verified the TRM TR LEFM system will be ML13043A659) 3.3.7.3, "Feedwater Flow Instrumentation" included in the TRM.

Due Date: Prior was updated with limitations for inoperable Technical Requirements Manual, to startup from LEFM system.

Volume I the sixteenth refueling outage Completed:

I 3/28/14 20306 A process will be Letter NRC-13-0004, dated February Ongoing-Closed. The startup from the RF16 outage implemented to use the 7, 2013 (ADAMS Accession No.

Closed was on 4/5/14. Verified the System LEFM feedwater flow to ML13043A659)

Operating Procedure 23.615.04 was adjust or correct the existing Due Date: Prior revised to add LEFM to Venturi correction feedwater flow venturi-based 23.615.04, Revision 6, "Leading Edge to startup from factor and changed core power to 3486 signals.

Flow Meter (LEFM)"

the sixteenth MWt based on LEFM providing more refueling accurate feedwater flow input to the core outage thermal power calculations.

Completed:

3/24/14

3 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 20307 Plant maintenance and Letter NRC-13-0004, dated February Ongoing-Closed. The startup from the RF16 outage calibration procedures will 7, 2013 (ADAMS Accession No.

Closed was on 4/5/14. Verified CARD 13-20171-be revised to incorporate ML13043A659) 17 documents Cameron's vendor Cameron's maintenance and Due Date: Prior recommendations and associated Fermi 2 calibration requirements.

Condition Assessment Resolution to startup from PM events: UT feedwater piping Initial preventive Document action 13-20171-17 the sixteenth downstream of LEFM every 18 months (PM maintenance scope and refueling Events F602 and F604), calibration of the frequency will be based on outage feedwater pressure instruments per vendor recommendations.

manufacturer's recommendations for Completed:

frequency (PM Events Y822 and Y823),

3/24/14 and checks of the RTDs per manufacturer's recommendations for frequency (PM Events Y824, Y825, Y826, and Y827).

20308 Modifications for the power Letter NRC-13-0004, dated February One Time-Closed. Verified that the associated Work uprate will be implemented.

7, 2013 (ADAMS Accession No.

Closed Orders were all complete and returned to ML13043A659) service by 3/26/14.

Due Date: Prior MIC WO No: 35443469, "MIC WO:

to startup from Noted that part of the scope was missed EDP-36969" the sixteenth during initial implementation. A corrective refueling action resolution document was issued to outage capture needed revisions to the Power to Flow Map and created the associated work Completed:

order. The work order was completed on 3/26/14 5/7/14.

4 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 20309 Necessary procedure Letter NRC-13-0004, dated February Ongoing-Closed. The startup from the RF16 outage revisions for the power 7, 2013 (ADAMS Accession No.

Closed was on 4/5/14. Verified in LCR 12-046-uprate will be completed.

ML13043A659)

OPL a list of documents required for Due Date: Prior implementation of the MUR were certified Licensing Change Request 12-046-to startup from to have been revised 3/19/14.

OPL the sixteenth refueling outage Completed:

3/25/14 20310 The plant simulator will be Letter NRC-13-0004, dated February One Time-Closed. The startup from the RF16 outage modified for the uprated 7, 2013 (ADAMS Accession No.

Closed was on 4/5/14. NANT-14-0029, dated conditions and the changes ML13043A659) 3/19/14 described the updated simulator will be validated in Due Date: Prior configuration will be made available for accordance with plant NANT-14-0029, "Simulator MAR2014 to startup from training use on March 28, 2014 and that the configuration control Configuration Update the sixteenth Cycle 17 core model update and processes.

refueling modifications associated with the MUR outage were included in the update.

Completed:

3/24/14

5 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 20311 Operator training will be Letter NRC-13-0004, dated February One Time-Closed. The startup from the RF16 outage completed prior to 7, 2013 (ADAMS Accession No.

Closed was on 4/5/14. Verified that Just-in-Time implementation of the ML13043A659)

Training LP-GN-909-1131AC contained proposed power uprate Due Date: Prior modifications to support MUR Power changes.

Just-in-Time Training LP-GN-909-to startup from Uprate.

1131AC, Revision 0.

the sixteenth refueling Condition Assessment Resolution outage Document 13-20404-121 Completed:

1/2/14 20312 Plant testing for the proposed Letter NRC-13-0004, dated February One Time-Closed. Verified that feedwater response changes will be completed as 7, 2013 (ADAMS Accession No.

Closed and pressure regulator response at 3 described in NRC-13-004, ML13043A659) distinct power levels was tested and data, Section 10.4, Due Date:

was collected. Results documented in IPTE "Testing."

IPTE 13-06, Revision 0, "Infrequently 5/30/14 13-06. IPTE 13-06 completed on 5/13/14.

Performed Test or Evolution Review and Approval Request" Completed:

5/13/14 20313 Plant-specific analyses for all Letter NRC-13-0004, dated February One Time-Closed. Verified that 0000-0158-9424-potentially limiting events will 7, 2013 (ADAMS Accession No.

Closed SRLR contains cycle specific analyses for be performed on a cycle ML13043A659) the limiting events.

specific basis as part of the Due Date: Prior reload licensing process.

0000-0158-9424-SRLR, Revision 0, to startup from "Supplemental Reload Licensing the sixteenth Report for Enrico Fermi 2, Reload 16 refueling Cycle 17" outage Completed:

11/1/13

6 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 89639 From ASME Section XI, IWA-Letter NRC-14-0024, dated July 2, Ongoing -

Closed for RF16. The startup from the 6000, submit to NRC 2014 (ADAMS Accession No.

Closed RF16 outage was on 4/5/14. Verified that lnservice Inspection ML14183B531)

NRC-14-0024 contains the required ASME Summary Report within 90 Due Date: 90 ISi Summary Report, and that it was days of completion of the days after RF 16 submitted within 90 days of the completion inspections.

of RF16.

Completed:

7/02/14 20360 Demonstration of compliance Condition Assessment Resolution One Time-Closed. The licensee performed an with Open Phase Condition Document (CARD) 12-21132, Closed investigation and further analysis, and (OPC) criteria through "Evaluate OE35219 (Preliminary -

identified action items to demonstrate analysis or identify Automatic Reactor Trip and Loss of Due Date:

compliance with the OPC criteria.

appropriate actions required Offsite Power Due to Failed 12/31/14 Additionally, the licensee responded to the to demonstrate compliance Switchyard Insulator) for applicability to Bulletin and subsequent RAls. NRC by 12-31-14 (see BL 2012-Fermi" Completed:

0007 contains responses to RAls asked in 01, NRC-14-0007, and NEI 12/19/14 reference to Bulletin 2012-01. In the letter to NRC (ADAMS CARD 12-26431, "NRC Bulletin 2012-response to an RAI, DTE Energy stated Accession No.

01, Design Vulnerability in Electric 10/24/12 that it has committed to the schedule ML13333A147)

Power System" (response to provided in the Industry OPC Initiative, and Bulletin 2012-it is DTE's intention to meet the milestones Letter NRC-14-0007, dated January 01); 1/30/14 of the schedule.

30, 2014 (ADAMS Accession No.

(response to ML14031A434)

RAI)

7 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 88047 IE 87-028-04 Violation Document Change Request (OCR) 12-One Time-This commitment was originally selected Response: Revise 1020, dated 10/19/12: MES03 Closed because it was identified by the licensee as Procedure 12.000.53 to Revision 8, "Identification of QA Level "deleted." According to the licensee's provide clarification on how to 1 and QA Level 1 M Structures, Due Date:

procedure for commitments (MLS10, identify which instruments Systems, and Components" 1/30/88 Revision 13), commitments can be deleted should be considered tech if the commitment was incorrectly classified spec related and treated as Completed:

as an ongoing commitment; or if the safety related.

5/21/13 committed action is met and the subject of the commitment is not being altered and the commitment is greater than 2 years old (i.e., Sunset Deleted).

The NRC staff reviewed the commitment and determined that Procedure MES03 contains guidelines to use in determining which structures, systems, and components are safety related. OCR 12-1020 documents the history of the commitment and ultimately the revision to MES03, from which the commitment was deleted. The OCR identified that RACTS item 88047 (the commitment) can be reclassified as one-time closed. Per MLS10, the commitment can be deleted.

The completion date noted is the date on which MES03 was revised.

12.000.53, Revision 5 was issued on 1/28/88

8 RACTSNo.

Description of Commitment Documents Reviewed Status Auditor's Assessment 95144 LER 95-007 included the Letter NRC 95-0109, dated October One Time-:-

This commitment was originally selected following commitment:

27, 1995 (LER)

Closed because it was identified by the licensee as Existing procedures will be "deleted." According to the licensee's revised or new procedures OCR 10-1603 for Procedure Due Date:

procedure for commitments (MLS 10, will be developed to ensure 24.307.41,Revision 25 "Functional Startup from Revision 13), commitments can be deleted positive verification that after Test of EOG 11 Load Sequencer MCC next plant if the commitment was incorrectly classified the EOG starts, the 480-volt Contacts" outage (i.e.,

as an ongoing commitment; or if the MCC automatically RF5 - 1/3/97) committed action is met and the subject of connected loads are OCR 10-1604 for Procedure the commitment is not being altered and energized through the load 24.307.42,Revision 25 "Functional Completed:

the commitment is greater than 2 years old sequencer.

Test of EOG 12 Load Sequencer MCC 10/30/13 (i.e., Sunset Deleted).

Contacts" Procedures were originally revised on OCR 10-1605 for Procedure 12/12/96. Procedures were subsequently 24.307.43,Revision 25 "Functional updated on 10/30/13 and the commitment Test of EOG 13 Load Sequencer MCC was changed to one-time closed. This Contacts" commitment was subsequently "sunset deleted" in accordance with MLS 10 OCR 10-1606 for Procedure because the committed action was met and 24.307.44, Revision 25 "Functional the commitment was greater than 2 years Test of EOG 14 Load Sequencer MCC old.

Contacts"

9 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 20295 Assets not currently available Letter NRC-12-0075, November 26, One Time-Closed. CARD 12-24852-08 documents for inspection will be 2012 (ADAMS Accession No.

Closed that seismic walkdowns of previously inspected no later than during ML12341A362) unavailable assets were completed on refueling outage 16 (RF16},

Due Date:

March 19, 2014 (during RF16).

currently scheduled for the CARD 12-24852, "Fukushima 3/30/14 first quarter of 2014. These Response - NRC Request for assets are listed in Appendix Information Concerning Seismic Completed:

E of the Fermi 2 Seismic Hazard Reevaluations and 3/19/14 Walkdown Report.

Walkdowns," dated 5/31/12 CARD 12-24852-08, "RF16 - Seismic Walkdown of inaccessible assets,"

dated 12/03/12 20297 Watertight door RB-1 Letter NRC-12-0076, dated November One Time-Closed. The startup from the RF16 outage (A7000Y033) will be 26, 2012 (ADAMS Accession No.

Closed was on 4/5/14. Reviewed TMPE-14-0108 inspected during refueling ML12331A202) which provided a summary of activities outage 16 (RF16}, currently Due Date:

performed to support completion of the first quarter of 2014)

Internal Memo TMPE-14-0108, RF16 (currently commitment. Also reviewed the associated scheduled for the first quarter "Fukushima Flood Response, scheduled for Work Orders which showed completion of of 2014.

Completion of Visual Inspection of first quarter of the inspection and subsequent completion "Restricted Access" Item Watertight 2014) of the repairs.

Door RB-1 (A7000Y033), NEI 12-07 Walkdown Record Form Revision Completed:

3/25/14 W035334258 - Work Order for Inspection W035241635 - Work Order for Repair

10 RACTS No.

Description of Commitment Documents Reviewed Status Auditor's Assessment 20298 The results of the inspection Letter NRC-12-0076, dated November One Time-Closed. The startup from the RF16 outage of watertight door RB-1 will 26, 2012 (ADAMS Accession No.

Closed was on 4/5/14. Verified NRC-14-0042 be submitted within 90 days ML12331A202) contained results of inspection of watertight of the outage completion.

Due Date: 90 door RB-1 (A7000Y003), the degraded Letter NRC-14-0042, dated June 30, days following condition was entered into the plant 2014 (ADAMS Accession No.

completion of corrective action program, and the door ML141818168)

RF16 frame was repaired and the seal was replaced.

Completed:

6/30/14 99060 Per DECO Commitment in Letter NRC-99-0104 dated 12/22/1999 Ongoing-Reviewed commitment change evaluation Letter NRC-99-0104, Fermi Closed summary. The commitment is expanded to will comply with all three Commitment Change Evaluation cover periodic verification of 5 additional phases of the Motor Summary (MLS 10002)

Due Date:

Class D MOVs, not originally included in Operated Valve Periodic 9/25/12 the JOG commitment. NRC notified of Verification Joint Owner's Letter NRC 12-0067 dated November commitment change in licensee letter NRC Group (JOG).

5, 2012 (ADAMS Accession No.

Completed:

12-0067.

ML12318A302) 8/7/12 Reviewed 47.306.05, Revision 4 and 47.306.05, Revision 4, "MOV confirmed procedure was revised to Performance Evaluation Program incorporate instruction to determine the Cycle Selection." Dated 8/7/12 testing scope and test interval. Reviewed TMIS-12-0083 and confirmed a sample of Internal Memo TMIS-12-0083, "Scope the additional Class D MOVs were included of MOVs to be Tested in Cycle 16 and in the valves to be tested during Cycle 16 17 for Generic Letter 96-05" and Cycle 17.

ML15139A301 DORL/LPL3-1 /PM DORL/LPL3-1 /PM JRarikin KGreen 5/19/2015 5/20/2015 Sincerely, IRA!

Jennivine K. Rankin, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl3-1 Resource RidsNrrLAMHenderson Resource DORL/LPL3-1 /LA DORL/LPL3-1 /BC DORL/LPL3-1 /PM MHenderson DPelton JRankin (SFigueroa for) 5/19/2015 5/27/2015 5/27/2015