ML15215A494

Audit of the Licensees Management of Regulatory Commitments

ML15215A494
Person / Time
Site:	Saint Lucie
Issue date:	08/18/2015
From:	Farideh Saba Plant Licensing Branch II
To:	Nazar M Nextera Energy
Saba F
References
TAC MF5789, TAC MF5790
Download: ML15215A494 (30)

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• • • • ¥ Mr. Mano Nazar President and Chief Nuclear Officer Nuclear Division NextEra Energy P.O. Box 14000 Juno Beach, FL 33408-0420 August 18, 2015

SUBJECT:

ST. LUCIE PLANT UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MF5789 AND MF5790)

Dear Mr. Nazar:

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

Every 3 years, the NRC staff audits a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC." This office instruction provides the NRC staff and its stakeholders with guidance on managing regulatory commitments and ensures a common understanding of the handling of regulatory commitments made to the NRC staff by licensees for commercial nuclear power reactors.

The NRC staff performed an audit of Florida Power and Light's (the licensee's) commitment management program at St. Lucie during the period May 26 through 29, 2015. The audit reviewed commitments made since the previous regulatory commitment audit was completed for St. Lucie on November 16, 2012. During the audit the NRC staff communicated the following general recommendations to the licensee: (1) that the commitment completion date should reflect the date that the licensing engineer or manager has confirmed the associated action has been properly executed; (2) that items specifically identified as regulatory commitments in written correspondence with the NRC should be designated as such in the licensee's tracking system (i.e., items should be tracked as regulatory commitments vs.

obligations or licensee planned actions); and (3) that changes to regulatory commitment designations in the licensee's tracking system should be documented with equivalent action requests cross-referenced for ease in tracking. The licensee generated three condition reports to address the NRC recommendations.

In addition, the NRC auditors communicated with Region II and NRR technical staff to assess implementation of the licensee's commitment change procedure in relation to a commitment change justification. The NRC staff concluded that the licensee's change was properly noticed to the NRC consistent with NEI 99-04 guidance. The NRC staff concludes that, based on the audit: (1) the licensee has implemented NRC commitments on a timely basis; (2) the licensee has implemented an effective program for managing NRC regulatory commitment changes that is consistent with the guidance in NEI 99-04; and (3) all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews. Details of the audit are set forth in the enclosed report.

Should you have any questions regarding this letter, please contact Candace Pfefferkorn at 301-415-8395 or candace.pfefferkorn@nrc.gov, or me at 301-415-1447 or farideh.saba@nrc.gov.

Docket Nos.: 50-335 and 50-389

Enclosure:

Audit Report cc w/encl: Distribution via Listserv Sincerely, p ~-/;cl_/. Z- ;;::_ ~ <-

Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

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~o UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS ST. LUCIE PLANT UNIT NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389

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 99-04 guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC. NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

Every 3 years, the NRC staff audits a licensee's commitment management program in accordance with the NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC." This office instruction provides the NRC staff and its stakeholders with guidance on managing regulatory commitments and ensures a common understanding of the handling of regulatory commitments made to the NRC staff by licensees for commercial nuclear power reactors.

NRR guidelines direct the NRR Project Manager to audit Florida Power and Light's (FPL's, the licensee's) commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit further includes evaluation of the licensee's commitment management procedures as compared to NEI 99-04 guidance, assessment of the licensee's commitment tracking database capabilities, appraisal of procedures for changing commitments (for both internal licensee management and communication with the NRC), and verification that no commitments were misapplied.

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

2.1 Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation. The audit also verifies that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.1.1 Audit Scope of Licensee's Implementation of NRC Commitments The audit addressed commitments initiated during the review period from November 16, 2012, to May 29, 2015, and commitments that were in progress at the beginning of the audit period (November 16, 2012). The audit focused on regulatory commitments made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation were included in the sample, but the review was limited to verification of restoration of compliance, not the specific methods used to restore compliance. Before the audit, the NRC staff searched the Agencywide Documents Access and Management System (ADAMS) for the regulatory commitments in the licensee's submittals and the NRC staff's safety evaluations during the audit period and compiled all relevant regulatory commitments.

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

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

1.

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

2.

Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

3.

Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and updated final safety analysis reports (UFSARs). Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results of Licensee's Implementation of NRC Commitments Prior to the audit, the licensee provided NRC staff lists of regulatory commitments related to licensing actions from the Nuclear Asset Management System (NAMS), the licensee's system used for commitment management, as well as the pertinent regulatory commitment management procedures. The licensee's lists of regulatory commitments included: (1) all open commitments; (2) all commitments initiated since November 16, 2012; (3) all commitments closed within the audit window; and (4) all commitments that have been changed during the last 3 years that were reported to NRC. For each commitment listed, the licensee provided a NAMS tracking number, commitment description, FPL letter number, ADAMS accession number, commitment due date, commitment completion date, and implementing documents.

Implementing documents for most of the closed commitments were provided to NRC staff prior to the audit via a file transfer protocol server; however, access to NAMS and additional supporting documentation such as commitment change evaluation forms was provided as requested by NRC staff during the on-site audit.

The licensee's commitment management program and tracking procedures are described in NextEra Energy Nuclear Fleet Administrative Procedure Nos. Ll-AA-101-1005, Revision 2, "NRC Commitment Management," and No. Ll-AA-101-1005-10000, Revision 1, "Commitment Tracking," respectively. The NRC staff found that Ll-AA-101-1005, Revision 2, and Ll-AA-101-1005-10000, Revision 1, provide guidance to the licensee that is consistent with the intent of NEI 99-04, and ensures that the licensee is appropriately implementing regulatory commitments.

The NAMS database is used for all nuclear plants in the NextEra fleet (FPL's parent company),

including St. Lucie, and provides a central nexus for tracking plant actions (e.g., licensee planned actions, obligations, regulatory commitments, etc.). As described in Ll-AA-101-1005-10000, Revision 1, for regulatory commitments, a licensing engineer reviews all correspondence incoming from and outgoing to the NRC for regulatory commitments and if applicable, enters the regulatory commitment(s) into NAMS. NAMS items are assigned an action request (AR) type and assignment type. For regulatory commitments, the designation is UC and COMM for AR and assignment type, respectively. If the required action is already being tracked, the licensing engineer ensures the wording of the action accurately describes the action required to manage the regulatory commitment and adds cross references to the existing NAMS tracking item, as applicable for tracking purposes. The licensing engineer is also responsible for designating the responsible organization (RO) for implementing the action and reviewing the closure documentation for completeness and accuracy. It is the responsibility of the licensing engineer to either close the action or reject the completion documentation.

Procedure Ll-AA-101-1005-10000, Revision 1, specifies that the RO assigned to complete the required action should upload closure documentation/objective evidence in NAMS by the agreed upon due date. Example acceptable closure documentation includes issued updated procedures indicating the procedure step addressing the commitment and notation in the reference section, plant modification closeout packages with acceptance by Operations, copies of completed work package cover sheet, or copies of cover letters or references to the appropriate document tracking number.

During the audit NRC staff interviewed the St. Lucie personnel and reviewed documentation in NAMS for the regulatory commitments detailed in the enclosure in order to assess the implementation of each regulatory commitment, including the completion status. For the commitments selected for the audit, the NRC staff found that the licensee had adequately captured implementation documents in their system consistent with their Procedures Ll-AA-101-1005, Revision 2, and No. Ll-AA-1O1-1005-10000, Revision 1.

The NRC staff noticed that some of the commitment descriptions provided in the detailed summary in NAMS did not always capture the exact wording of the regulatory commitment or provide a clear link to the originating document. NAMS detailed description fields are fully searchable and therefore, a recommendation was made to the licensee to include the exact wording from written correspondence to enhance commitment tracking/comparison of NAMS content against ADAMS docketed source documents.

No open commitments were past the due date listed in NAMS. For completed commitments, the NRC staff confirmed implementation documents were uploaded into NAMS prior to the commitment due date listed or inferred from official source documentation. The NRC staff did not find any commitments that were completed past their due date; however, it was noted that the completion date listed was the date that the RO confirmed implementation in NAMS and not the licensing engineer or manager. Per Ll-AA-101-1005, Revision 2, and No.

Ll-AA-101-1005-10000, Revision 1, the licensing engineer is responsible for reviewing the closure documentation for completeness and accuracy and for either closing the action or rejecting the completion documentation. In addition, NRC staff noted a few commitments that were completed past internal licensee deadlines listed in NAMS. NRC staff made a recommendation to the licensee to ensure that the commitment completion date reflect the date that the responsible licensing engineer or manager has confirmed the associated action has been properly executed.

NRC staff evaluation of NAMS due dates compared to that listed in source documentation in ADAMS revealed that several commitment due dates were not listed in NRC source documentation. While the due dates listed in NAMS were not inconsistent with the intent of the source document, the NRC staff informed the licensee that due dates should be listed for all commitments in the written correspondence to the NRC.

The NRC staff-generated commitment list based on surveying licensing-related source documents was compared to the lists provided by the licensee. Several regulatory commitments designated in source documentation were not included in lists provided by the licensee. NRC staff identified that this was because these regulatory commitments were not assigned the AR and assignment types, UC and COMM, respectively. Discussion with the licensee revealed that some commitments were voluntarily elevated to assignment type obligation (OBLG) to ensure a high priority tracking and completion status. In addition, some regulatory commitments were designated LICA, for licensee planned actions. While no deficiencies were observed in the implementation of commitments listed under different ARs or assignment types, NRC staff recommended that items specifically identified as regulatory commitments in written correspondence with the NRC should be designated as such in the licensee's tracking system and that changes to regulatory commitment designations in the licensee's tracking system should be documented with equivalent action requests cross-referenced for ease in tracking.

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The audit also verifies that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process. The process used at St. Lucie is contained in procedure Ll-AA-101-1005, Revision 2, which is based on and implements the recommendations of NEI 99-04. While the audit scope included commitment changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC, only the latter was audited because no items fell into the category of the former.

2.2.1 Audit Results of the Licensee's Program for Managing NRC Commitment Changes The NRC staff reviewed the licensee's procedure Ll-AA-101-1005, Revision 2, against NEI 99-04 to ensure that guidance in this procedure is consistent with the intent of NEI 99-04, and that St. Lucie is appropriately implementing regulatory commitment changes, as well as tracking changes to the commitments.

The NRC staff found that Ll-AA-101-1005, Revision 2, adequately conforms to the guidance and intent of NEI 99-04 for commitment tracking, the commitment change process, traceability of commitments, and reporting requirements. Regulatory commitment changes are processed and tracked by the responsible licensing engineer, or designee. The evaluation of any commitment changes is to be done by filling out the "Commitment Change Evaluation Summary Checklist, Form Ll-AA-101-1005-F01, instructions for which can be found in Attachment 1 of Ll-AA-101-1005, Revision 2. The NRC staff reviewed this form and found it consistent with the intent of the "Commitment Evaluation" form in NEI 99-04.

During the audit, the licensee provided documentation for all commitments in which a Commitment Change Evaluation Summary Checklist Form had been completed. While the audit scope included commitment changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC, only the latter was audited because no items fell into the category of the former (see 2012, 2013, and 2014 annual summaries of commitment changes implemented; ADAMS Accession Nos. ML13071A418, ML14071A018, and ML15065A236, respectively).

Of the two commitment changes evaluated, both were properly routed outside of the commitment change process after evaluation at Part I, Step 3 of the licensee's Commitment Change Evaluation Summary Checklist Form. Specifically, the commitment changes were routed for change via another already codified process (e.g., 10 CFR 50.71e, 10 CFR 50.54, and 10 CFR 50.59).

The NRG staff also reviewed a commitment change justification notification letter (ADAMS Accession No. ML13025A208) that was submitted by the licensee during the audit review period. While the justification did not change the commitment, the original commitment change notification (ADAMS Accession No. ML003769058) was also reviewed. The licensee notified the NRG of both the commitment change and the commitment change justification; however, NRG approval of the change was not requested. If a commitment change is significant to safety, per NEI 99-04 (Figure A 1 ), NRG approval is required. Subsequent to the audit, NRG regional and technical staff reviewed this commitment change to determine if the change was significant to safety. The staff concluded that the licensee's change did not compromise safety and, therefore, the commitment change was properly noticed to the NRG consistent with the NEI 99-04 guidance.

Based on the audit, the NRG staff found that the licensee is adequately implementing the procedures and instruction for managing regulatory commitments in the Ll-AA-101-1005, Revision 2, which is consistent with the intent of NEI 99-04 guidelines pertaining to 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 NRG staff relied on the action comprising the commitment in making a regulatory decision such as a finding of public health and safety in an NRG safety evaluation associated with a licensing action. Reliance on an action to support a regulatory decision must be elevated from regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (i.e., commitments used to ensure safety).

Each of the commitments included in the audit were reviewed to determine if any had been misapplied. No commitments were found to be misapplied.

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

2.4 Audit Observations and Suggestions During the audit the NRG staff communicated the following observations and suggestions to the licensee:

(1)

The NRC staff did not find any commitments that were completed past the due date listed in written correspondence with the NRC; however, it was noted that the completion date listed in NAMS was the date that the RO confirmed implementation in NAMS and not the licensing engineer or manager. Per Ll-AA-101-1005, Revision 2, and No. Ll-AA-101-1005-10000, Revision 1, the licensing engineer is responsible for reviewing the closure documentation for completeness and accuracy and for either closing the action or rejecting the completion documentation. The NRC staff suggested to the licensee that the commitment completion date should reflect the date that the licensing engineer or manager has confirmed the associated action has been properly executed.

(2)

The due dates listed in NAMS were consistent with the intent of the source correspondence document; however, some source documents did not include due dates. The NRC staff suggested to the licensee to clearly define due dates for all regulatory commitments contained in written correspondence with the NRC.

(3)

While some commitments contained the exact wording of the commitment in the detailed description field in NAMS, most commitments did not contain exact wording and/or reference the ADAMS Accession No. in addition to the licensee's letter number. A suggestion was made to the licensee to include the exact wording from written correspondence to enhance commitment tracking as well as comparison of NAMS content against ADAMS docketed source documents.

(4)

Several items were not included in the licensee's list of commitments provided to the NRC staff prior to the audit. The NRC staff suggested that items specifically identified as regulatory commitments in written correspondence with the NRC should be designated as such in NAMS and that changes to regulatory commitment designations should be should be documented with equivalent action requests cross-referenced for ease in tracking.

(5)

The NRC staff observed that some incoming licensee documentation did not contain a separate section or attachment that clearly identified regulatory commitments.

Therefore, the NRC suggested that all correspondence should clearly state that commitments are contained (or not contained) in the documents and include a separate section or attachment with the regulatory commitments in a consistent table format for clarity and ease of tracking.

The licensee's staff acknowledged the NRC staff observations and recommendations and created the following ARs:

AR No: 02050236,

Subject:

NRC Observation: Regulatory Commitment Completion Dates, Due Date - Aug 20, 2015 o

==

Description:==

"During the 2015 NRC audit of regulatory commitments at St. Lucie, the NRC auditors observed that the St. Lucie had a delayed review of commitment completions by having the LIC MGR as the 'owed to' for the related AR rather than having a more timely review, such as with the assignment routing list. The delay could be an undesired condition if the AR closure reviews identify assignment closure gaps."

o Immediate Actions: "The Licensing Manager was added as an approver to each open PSL COMM assignment. This will ensure a timely licensing manager review for each PSL [St. Lucie] COMM assignment."

AR No. 02050248,

Subject:

NRC Observation: NAMS Updates to Regulatory Commitment Assignment, Due Date - Aug 20, 2015 o

==

Description:==

"During the 2015 NRC audit of regulatory commitments at St. Lucie, the NRC auditors observed that NAMS updates to regulatory commitment assignments do not always include the basis for the update. For example, if Licensing identifies that a regulatory commitment (COMM) assignment should be tracked as an obligation (OBLG) assignment; the change was often just made without additional in-progress notes. It would be appropriate to include in-progress notes for this type of change."

o Immediate Actions: This feedback was received by the PSL Licensing commitment management program owner and shared as coaching with the PSL Licensing staff."

AR No: 02050905,

Subject:

NRC Observation: Assignment Types for Regulatory Commitments o

==

Description:==

"NRC Observation: Assignment types for regulatory commitments during the 2015 NRC audit of St. Lucie regulatory commitments, the NRC auditors identified some regulatory commitments that were tracked as OBLG and LICA assignment types. The auditors recommended that the assignment types should be COMM assignment types."

o Immediate Actions: "The following assignments were updated in NAMS:

01746246-19 Changed from OBLG to COMM on 5/28/15 01872955-06 Changed from LICA to COMM on 5/28/15 01872955-07 Changed from LICA to COMM on 5/28/15 These changes do not affect how the actions will be implemented and will allow easier retrieval of the assignments during future commitment audits."

3.0 CONCLUSION

The NRC staff concludes that, based on the audit: (1) the licensee has implemented NRC commitments on a timely basis; (2) the licensee has implemented an effective program for managing NRC regulatory commitment changes that is consistent with the guidance in NEI 99-04; and (3) all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Richard Sciscente, Principal Engineer, St. Lucie Licensing Atanya Lewis, Principal Engineer, Nuclear Fleet Support Services Ken Frehafer, Principal Engineer, St. Lucie Licensing Principal Contributors: Candace M. Pfefferkorn Farideh E. Saba Date: August18, 2015

Attachment:

Summary of Audit Results

1 Summary of Regulatory Commitment Audit Results St. Lucie, Units 1and2 Audit Period: November 15, 2012 - May 29, 2015 No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

I MLl3057 AI08 L-2013-048 St. Lucie will commit to provide 09/16/13 09/16/13 TS Bases updated on Closed This commitment was 02/13113 a description of the averaging 09/12/13 correctly implemented via the 1731002-02 method used in the Technical In Amendment TS Bases Program. The (MLl3150A33 Specifications Bases Section.

Safety Evaluation commitment was generated 7 - Issued The proposed addition to the (SE) dated through the request for Amendment)

Technical Specification Bases 06/18/13 revised information (RAJ) process in 06/18113 document is shown in bases pages were response to a license to this enclosure.

submitted but amendment request (LAR).

referred to the This commitment was not In addition, St. Lucie proposes Technical specifically notated as such in enhancing the Table and text in Specifications a separate section of the the Technical Specification (TS) Bases source documentation. The Surveillance Requirements (Unit Control Program commitment was also not I TS SR 4.8.2.3.2.c.3 and Unit 2 stated verbatim from the TS SR 4.8.2.1.c.3) in the source document in the proposed License Amendment detailed description in NAMS.

request to describe the definition This commitment was not of 50 µQ per cell "average" listed as part of the licensee's value, as shown below and in list of commitments prior to Attachments 3 and 4:

the audit because it was not tracked in NAMS under the UC-COMM designation (tracked as obligation, OBLG).

2 MLl4077A265 L-2013-233 FPL will establish the Technical 04/28/15 04/24/15 Unit I and Unit 2 TS Bases Closed This commitment was 02/26/14 Specification Bases for LCO correctly implemented via TS 1946199-10 3.0.4 and SR 4.0.4 as adopted Bases Program. This with this license amendment commitment was not stated request.

verbatim from the source document in the detailed Attachment No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

description in NAMS. This commitment was not listed as part of the licensee's list of commitments prior to the audit because it was not tracked in NAMS under the UC-COMM designation (tracked as OBLG).

3 ML13025A208 L-2013-005 Commitment regarding Generic Each Each outage Inspection Procedures Ongoing In 2013, the licensee updated a 01/10/13 Letter (GL) 89-13 outage commitment change justification for a commitment ML003769058 L-2000-215 The Commitment changed the change executed in 2000 11/09/00 routine inspection interval for the associated with GL 89-13.

Units I and 2 intake well and The updated commitment safety-related intake cooling change justification did not water (!CW) piping from 100%

change the commitment.

every refueling outage to a single train inspection every refueling NRC staff reviewed the outage. This change will result in original commitment change I 00% inspection of the intake requested by the licensee in well and !CW piping every other 2000, but were unable to refueling outage for each unit.

review the original commitment change evaluation summary form because the commitment pre-dated licensee's commitment change procedures. To ensure this commitment change was executed in accordance with NEI 99-04, NRC regional and technical staff reviewed the commitment for safety significance. NRC staff concluded that this commitment change was executed by the licensee in accordance with NE! 99-04.

No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

4 MLI 4329A205 L-2014-345 For St. Lucie Unit 1, all required (End of 4/20/15 FPL L-2015-143 Closed This commitment was not 11/20/14 procedures, guidance, training, outage)

Licensee compliance matrix stated verbatim from the 01746246-18 and acquisition, staging, or 4/25/15 for the umbrella modification source document in the installing of equipment necessary verified complete.

detailed description in NAMS.

to implement the Diverse and This commitment was not Flexible Mitigation Capability listed as part of the licensee's (FLEX) strategies will be list of commitments prior to complete prior to the conclusion the audit because it was not of SLl-26 spring refueling tracked in NAMS under the outage.

UC-COMM designation (tracked as OBLG).

5 ML14329A205 L-2014-345 For St. Lucie Unit 2, all required (End of Open This commitment was not 11/20/14 procedures, guidance, training, outage) stated verbatim from the 01746246-19 and acquisition, staging, or 10/09/15 source document in the installing of equipment necessary detailed description in NAMS.

to implement the FLEX strategies This commitment was not will be complete prior to the listed as part of the licensee's conclusion ofSL2-22 fall list of commitments prior to refueling outage.

the audit because it was not tracked in NAMS under the UC-COMM designation (tracked as OBLG).

6 ML12307Al 16 L-2012-377 Existing on-site communications 04/30/13 04/30113 Licensee Summary:

Closed This commitment was not 10/31/12 systems improvements 18 portable radios in smart listed as part of the licensee's 1746245-07 and their required normal and/or chargers have been moved to list of commitments prior to backup power supplies the Computer room in the the audit because it was not

- Develop procedural guidance to TSC complex. Operation of tracked in NAMS under the recharge portable radio batteries.

the Interim FLEX 6kW UC-COMM designation

- Develop procedural guidance to Diesel Generator, 0-NOP-(tracked as OBLG).

periodically test portable 99.08 was approved on generators.

4/22/13 and has instructions

- Additional portable radios will for the operations of 6 KW be stored in the Technical Diesel and charging batteries.

Support Center EC 278700 Design Change Package NRC 1 OCFR50.54(F)- Near Term Task Force Rec 9.3 -

No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

Emergency Preparedness -

Communications Charging Equipment Storage 7

ML12307Al 16 L-2012-377 Off-site communications systems 04130113 04/30/13 Licensee Summary:

Closed This commitment was not 10/31/12 improvements and their required 5 additional portable satellite listed as part of the licensee's 1746245-08 normal and/or backup power phones have been placed in list of commitments prior to supplies; the TSC and 4 in the EOF.

the audit because it was not

• Acquire Government Credit was taken for the tracked in NAMS under the Emergency Telecommunications diesel at the EOF. A portable UC-COMM designation Service (GETS) and the Wireless diesel is being maintained (tracked as OBLG).

Priority Service (WPS) cards for available in Vent Stack communication links as Radiation Monitor Room that appropriate.

meets the storage

• Develop procedural guidance to requirements of9.3 see EC recharge portable satellite phone 278700. Instructions for the batteries.

operation of the diesel and

• Develop procedural guidance to charging batteries is provided periodically test portable in O-NOP-99.08 Operation of generators.

the Interim Flex 6KW Diesel

• Additional portable satellite Generator.

phones will be stored in the Technical Support Center and the GETS numbers 97855736 and Emergency Operations Facility.

22808437 have been assigned Off-site communications to PSL for GETS capability.

There currently are no assigned cell phones to key ERO communicators at St. Lucie that require WPS.

8 MLl2307Al 16 L-2012-377 Off-site communications systems 04105115 02/27/15 EC279287 is complete. This Closed This commitment was not 10/31/12 improvements installed a docking station listed as part of the licensee's 1746245-09

• Install satellite phone fixed with an external antenna in list of commitments prior to antennas and docking stations in Unit 2 Control Room and 5 the audit because it was not Emergency Response Facilities.

docking stations with external tracked in NAMS under the antennas in the TSC/Control UC-COMM designation Room envelope. 4 docking (tracked as OBLG).

stations with external antennas were installed at the EOF.

No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

9 ML082900487 L-2008-221 FPL is continuing to support the 8/29/14 07/16/14 L-2014-029 Closed There were two commitments I 0/14/08 industry and NE! Gas ML l 4198A074 included in L-2008-221. Only 0554250-26 Accumulation Management Team one is included in this audit activities regarding the resolution because the other commitment of generic TS changes via the was closed on 12/15/09 which Technical Specification Task is outside this audit window.

Force (TSTF) traveler process.

FPL will evaluate the resolution This commitment was not of TS issues with respect to the stated verbatim from the changes contained in the TSTF source document in the traveler following NRC approval detailed description in NAMS.

and the Consolidated Line Item Improvement Process (CLIIP)

Notice of Availability of the TSTF traveler in the Federal Register. Based upon the results of the evaluation, an appropriate license amendment request will be filed with the NRC within 180 days following NRC approval of the TSTF. The appropriate Bases changes associated with the potential Technical Specification will also be made.

10 ML! I 0730116 L-2011-021 EPU !ST Changes 11/14/12 11/18/12 ADM-29.0IA Closed Source documentation did not ML! I 0730310 L-2011-021 I. Update the Inservice Testing specify an exact completion (Attachment 7)

(Attachment 7)

Program to reflect changes to date. The licensee did not 02125111 plant pumps and valves under complete the action by the due 1711901-01 EPU conditions.

date listed in NAMS; however, the licensee explained this was an internally controlled due date and therefore the commitment was still completed in a time frame consistent with the source documentation.

A link to the implementing No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

documentation was not included in NAMS.

ll ML! 10730116 L-2011-021 EPU Operator Training 11/12/12 11/15/12 PSL OPS 0502521 SLl-24 Closed Source documentation did not ML110730310 L-2011-021

2. Provide operator training to Procedures Rev 00 specify an exact completion (Attachment 7)

(Attachment 7) account for increased EPU power PSL OPS 0508521 Rev 00 date. The licensee did not 02/25/l l level and resultant plant changes.

PSL OPS 0702521A R02 complete the action by the due 1711901-02 PSL OPS 0702521B ROI date listed in NAMS; PSL OPS 070252IC ROO however, the licensee PSL OPS 0702521D ROO explained this was an PSL OPS 0702521E ROO internally controlled due date PSL OPS 0702521F ROO and therefore the commitment PSL OPS 0702522 ROI was still completed in a time frame consistent with the source documentation.

12 MLI 10730116 L-2011-021 EPU Leading Edge Flowmeter 1/11/13 01/10113 EC 249978 Closed Source documentation did not MLI I 0730310 L-2011-021 Mod EC 249979 specify an exact completion (Attachment 7)

(Attachment 7)

3. Implement modification(s) to date. The implementing 02125111 install a leading edge flow meter documents in NAMS did not 1711901-03 (LEFM) as described in LR include the associated work Section 2.4.4, Measurement orders.

Uncertainty Recapture Power Uprate, and update UFSAR Section 13.7, Licensee-Controlled Technical Specification Requirements, to include Limiting Conditions for Operation (LCO) and Action Statements for the LEFM system.

13 MLI 10730116 L-2011-021 EPU RDF RTD Mod 11/13/12 11/02/12 EC 249988 Closed Source documentation did not MLI 10730310 L-2011-021

4. Implement modification(s) to specify an exact completion (Attachment 7)

(Attachment 7) replace RDF Corporation date. The implementing 02/25/11 resistance temperature detectors documents were specified in 1711901-04 as described in LR Section 2.3.1, NAMS but not cross linked.

Environmental Qualification of Electrical Equipment.

14 MLI 10730116 L-2011-021 EPU AC Bus Mods 12/31/12 11/30/12 EC 249965 Closed Source documentation did not MLI 10730310 L-2011-02 l

5. Implement modification(s) to specify an exact completion (Attachment 7)

(Attachment 7) the AC electrical busses as date. The implementing No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

2/25/11 described in LR Section 2.3.3, documents were specified in 1711901-05 AC Onsite Power System.

NAMS but not cross linked.

15 MLI 10730116 L-2011-021 EPU Pipe Support Mods 12/31/12 11/30/12 EC 249987 Closed Source documentation did not MLI I 0730310 L-2011-021

6. Implement modification(s) to EC 249992 specify an exact completion (Attachment 7)

(Attachment 7) pipe supports for systems EC 249986 date. This commitment is 02/25/11 impacted by loads due to EPU listed twice in NAMS (two 1711901-06 conditions, as described in LR different AR-AS nos.)

Section 2.2.2.2, Balance of Plant Piping, Components, and Supports.

MLI 10730116 L-2011-021 EPU Pipe Support Mods 12/31/12 11/30/12 EC 249987 Closed Source documentation did not MLI 10730310 L-2011-021

6. Implement modification(s) to specify an exact completion (Attachment 7)

(Attachment 7) pipe supports for systems date. This commitment is 02/25/11 impacted by loads due to EPU listed twice in NAMS (two 1653220-06 conditions, as described in LR different AR-AS nos.)

Section 2.2.2.2, Balance of Plant Piping, Components, and Supports.

16 MLI 10730116 L-2011-021 EPU Melamie insert 11/30/12 11/30/12 OSP 67.01 Source documentation for MLI 10730310 L-2011-021

7. Melamie insert surveillance these commitments did not (Attachment 7)

(Attachment 7) program as described in LR specify an exact completion 02-25-11 Section 2.8.6.2, Spent Fuel date. This commitment was 1711901-07 Storage, and update the UFSAR revised by L-2011-524 to include the program (licensee RAJ response) prior requirements to the granting of LAR (L-2011-021). Associated MLI 1364A043 L-2011-524 L-2011-524 revised this commitments were tracked 12-27-11 commitment:

using various designations in As described in EPU LAR NAMS (see below)., Section 2.8.6.2.2.6, the visual inspections will be at 4, 8, 12, 20, and 30 years after initial installation and the physical measurement inspections and neutron attenuation testing will be at 4, 12, 20 and 30 year intervals...

In accordance with the No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

manufacturer's recommendations... FPL will perform physical measurement inspections on coupons, not on the MetamicTM inserts as previously committed.

1751336-10 UNIT 2: Record Metamic CT 06/25/12 OSP 67.01 Closed These commitments were not installation date and SFP location listed as part of the licensee's list of commitments provided 1751336-16 UNIT 2: Record initial fuel 06/25112 OSP 67.01 Closed to the NRC prior to the audit configuration surrounding CT because they were tracked in NAMS under a RWA 1751336-17 Unit 2: Record fuel configuration 09/03/12 OSP 67.01 Closed designation. Commitment surrounding CT after U2C21.

descriptions summarized from licensee database.

1751336-18 UNIT 2: Record fuel 4130114 04/08/14 OSP 67.01 Closed This commitment was listed as configuration surrounding CT AR 1751336-18.pdf part of the licensee's list of after U2C21 commitments provided prior to the audit. This was tracked in NAMS under COMM designation.

1751336-19 UNIT 2: Record fuel 11/30/15 OSP 67.01 Open These commitments were not configuration surrounding CT listed as part of the licensee's after U2C22 list of commitments provided 1751336-11 UNIT 2: 4 Year Metamic 6/30/2016 OSP 67.01 Open to the NRC prior to the audit Surveillance Interval because they were tracked in 1751336-12 UNIT 2: 8 Year Metamic 6/30/2020 OSP 67.01 Open NAMS under a OBLG Surveillance Interval designation. Commitment 1751336-13 UNIT 2: 12 Year Melamie 6/30/2024 OSP 67.01 Open descriptions summarized from Surveillance Interval licensee database. The 1751336-14 UNIT 2: 20 Year Metamic 6/30/2032 OSP 67.01 Open licensee changed these Surveillance Interval assignments from OBLG to 1751336-15 UNIT 2: 30 Year Metamic 6/30/2042 OSP 67.01 Open COMM after NRC on-site Surveillance Interval audit.

17 ML! 10730116 L-2011-021 EPU CR AC Mods 12/31112 11/30/12 EC 249981 Closed Source documentation did not ML! I 0730310 L-2011-021

8. Implement modifications to the WO 40114036-58 specify an exact completion (Attachment 7)

(Attachment 7) control room air conditioning WO 40114036-60 date.

02/25/11 system as described in LR No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

1711901-08 Section 2.5.4.3, Reactor Auxiliary Cooling Water Systems, to accommodate higher component cooling water temperatures under EPU conditions.

18 ML12235A463 L-2011-453 Complete the modifications to I 0/31/12 03101112 The wave traps were removed Closed This commitment is listed in 09/24/12 remove the wave traps prior to as planned during SLl-24.

the issued amendment safety 01711901-10 operating St. Lucie 2 at its Work orders are not used for evaluation, but is not listed in EPU ratings as discussed in switchyard work. The NAMS original license LAR Section 2.3.2 Offsite Power assignment completion notes (Commitment #10 - 17 above).

System - Switchyard state that the removal of the Connections.

wave traps was confirmed by TSO personnel on 02/07/12.

19 ML12235A463 L-2011-453 Unit2:

07131113 07/22/13 ADM-17.29, Rev. I Closed This commitment is listed in 09/24/12 Adopt MRP-227-A in place of the ML12235A463, but is not existing R VI inspection program.

listed in original licensee ML! 1362A382 L-2011-556 LAR. This commitment 12/20/2011 aligns with the licensee 1851885-06 response to RAI CVIB-1 in ML! 1362A382.

20 ML! 1354A234 L-2011-545 L-2011-545 contains a 12/31/12 01107113 2-PMI-22.38 Closed Commitment for Unit 2 EPU 12/14/11 commitment to perform testing of 2-0SP-22.01 based on RAJ for Unit 1 EPU.

1711901-11 the turbine steam admission 2-0SP-22.03 The commitment was not valves and overspeed trip system 2-0SP-22.04 stated verbatim from the as noted below:

source document in the

• Testing of the speed probes will detailed description in NAMS.

be performed off-line at refueling The commitment completion intervals.

date was later then the due

• Testing of the speed detector date.

modules will be performed off-line at refueling intervals.

• Testing of the testable dump manifolds will be performed on-line at quarterly intervals.

• Testing of the turbine control system controller overspeed logic will be performed at refueling intervals.

No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

• Testing of the steam admission valves will occur at 6-month intervals.

21 MLl2340A352 L-2012-427 Complete U I deferred seismic 09/30/14 09126114 12Q4116-RPT-OOI, Rev. I Closed NAMS lists implementation (12Q4116-walkdowns (L-2012-427)

W040330038 -01 documents but they are not RPT-001 1746202-07 Unit I Seismic Report transmitted W040330036-0 l linked in the system. Page Rev. 0) via L-2012-427. Appendix E of 316 ofMLl2340A352 states 11/27/12 the Unit l Seismic Report that, "the plans for inspection (12Q4116-RPT-OOI Rev. 0) of inaccessible equipment are identified equipment that was to inspect the items during the inaccessible for inspection during first available equipment or the walkdown. Table E-1 refueling outage, when they identified equipment that is can be safely accessed. The located within containment and next schedule refueling outage could not be accessed because the is Fall 2013." The due date unit was at power during the time listed in NAMS was 09/30/14.

of the walkdown. Table E-2 The licensee provided identifies electrical cabinets that documentation at the on-site could not be opened due to audit that stated for cases electrical safety and plant where items were inaccessible operation hazard. 12Q4116-RPT-during the reporting period, an 001 Rev. 0 Appendix E continued updated submittal report and provided the following should be submitted later.

licensee planned action:

Therefore, the licensee was A plant Corrective Action has still in compliance with been issued to plan for and MLl2340A352.

implement additional cabinet internal inspections.

22 MLl2340A353 L-2012-427 Complete U2 deferred seismic 09/30/14 09/26/14 12Q4116-R-002, Rev. I Closed (12Q4116-R-walkdowns (L-2012-427) 002 Rev. 0) 1746202-08 Unit 2 Seismic Report transmitted 11/27/12 via L-2012-427. Appendix E of the Unit 2 Seismic Report (12Q4116-R-002 Rev. 0) identified equipment that was inaccessible for inspection during the walkdown. Table E-1 identifies equipment that is No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

located within containment and could not be accessed because the unit was at power during the time of the walkdown. Table E-2 identifies electrical cabinets that could not be opened due to electrical safety and plant operation hazard. 12Q4116-RPT-002 Rev. 0 Appendix E continued and provided the following licensee planned action:

A plant Corrective Action has been issued to plan for and implement additional cabinet internal insoections.

23 MLl3121A462 L-2013-147 Develop and implement a process 03/31/14 03/31/14 EPIP-04 Closed 04/30/13 to integrate the expanded EPIP-06 1746246-07 response capability into existing augmented ERO (i.e., put in place the ability to transition to unit-specific performance). Formalize this process via an EP procedure or similar guideline. (During performance of the N El 12-0 I Phase 2 assessment, the process will be re-assessed and revised as necessary).

a. This process is expected to provide flexibility to the Emergency Director and TSC Manager in establishing the expanded response capability based on site priorities at the time of the event.

b. The process will include implementing strategy and decisionmaking criteria for initiating the actions necessary to No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

ensure timely performance of expanded response functions.

c. The process will require the Emergency Director and TSC Supervisor to take into account the functions and recommended staffing considerations listed in NEI 12-01 Table 3.1 as they establish the "expanded response capability."

d. Provide training and or briefings, as appropriate, to ERO members prior to implementing this process.

e. Include provisions for a minimum number of available RPTs following a BDBEE, to support performance of assigned emergency plan functions and the expanded response capability.

Provide the equation in Section 3.5. I ofNEI 12-01 to the ERO personnel to use as a reference in determining the required number of on-site RPTs.

24 MLl3121A462 L-2013-147 Identify additional work areas 03/31/14 03/31/14 EPIP-04 Closed 04/30/13 necessary for the performance of EPIP-06 1746246-08 expanded response functions 25 MLl3121A462 L-2013-147 Identify area for the ERO to 12/20/13 12/12/13 COMM 1746246-09 Closed 04/30/13 assemble to following an event in completion notes 1746246-09 which normal plant access to the plant is not available. This would include any required letters of agreement for the use of this area.

26 MLl3121A462 L-2013-147 Provide training to the ERO for 12120113 12/17/13 ERO info sharing ~3.docx Closed 04/30/13 response to beyond designed 1746246-10 based accidents where alternate assembly staging may be required No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

27 MLl3121A462 L-2013-147 Evaluate additional resources that 03131114 03131114 EPlP-06 Closed 04130113 may be require for beyond design 1746246-11 based accidents and include in the applicable procedures 28 MLl3302A933 L-2013-302 FPL commits to implementing 12131114 12122114 EPlP-14 Closed 10116113 version 2.0 of the full multiunit/

1746246-12 multi-source dose assessment computer model RASCAL Unified Rascal Interface (URI) by December 31, 2014.

29 MLl3149A269 L-2013-168 Unit I:

0811113 07126113 COMM1872955-0I Closed Same FPL Tracking Number 05115113 FPL will schedule a meeting with completion notes assigned for #29 and #30 1872955-01 NRC to discuss this proposed resolution path.

30 MLl3149A269 L-2013-168 Unit2:

0811113 07126113 COMMI872955-0l Closed Same FPL Tracking Number 05115113 FPL will schedule a meeting with completion notes assigned for #29 and #30 1872955-01 NRC to discuss this proposed resolution path.

31 MLl3149A269 L-2013-168 Unit I:

09130113 09130113 L-2013-281 Closed Same FPL Tracking Number 05115113 FPL will provide a preliminary MLl3283A003 assigned for #31 and #32 1872955-02 schedule for completion of the risk-informed resolution path activities.

32 MLl3149A269 L-2013-168 Unit2:

09130113 09130113 L-2013-281 Closed Same FPL Tracking Number 05115113 FPL will provide a preliminary MLl3283A003 assigned for #3 I and #32 1872955-02 schedule for completion of the risk-informed resolution path activities.

33 ML13149A269 L-2013-168 Unit 1:

12131113 12119113 NIA Closed Completion notes in NAMS 05115113 FPL will complete measurements should have included more 1872955-04 for insulation replacement.

detai 1 to document why these 34 MLl3149A269 L-2013-168 Unit2:

05131114 05129114 NIA Closed commitments were closed.

05/15113 FPL will complete measurements Discussion with the licensee 1872955-04 for insulation replacement.

during the on-site audit revealed that these commitments did not have associated implementation documentation because no No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

action was necessary to close (L-2013-281, ML13283A003).

35 ML13149A269 L-2013-168 Unit 1:

12/31119 Open 05115113 FPL will complete any necessary 01872955-05 insulation replacements or remediation, or other identified olant changes.

36 ML! 3149 A269 L-2013-168 Unit 2: FPL will complete any 03131120 Open 05115113 necessary insulation replacements 01872955-09 or remediation, or other identified olant changes.

37 ML13149A269 L-2013-168 Unit 1: FPL will submit a final 01/31/17 Open Source documentation lists 05115113 updated supplemental response to completion for these 01872955-06 support closure ofGL 2004-02 commitments as within 6 months of the receipt of the SE 38 ML13149A269 L-2013-168 Unit FPL will submit a final 01131117 Open for the risk-informed 05115113 updated supplemental response to resolution licensing action.

01872955-07 support closure ofGL 2004-02 The completion date in NAMS was specific: 01/31/17. These commitments were not listed as part of the licensee's list of commitments provided to the NRC prior to the on-site audit because they were tracked in NAMS under a LICA designation.

39 MLl3284A058 L-2013-291 RE-26-62 repaired or special 10/25/13 10/23/13 Radiation monitor was Closed These compliance issues were 10/01113 report updated:

repaired.

listed in NAMS as 1907798-01 If the MSL radiation monitor, Commitments.

RE-26-62, is not restored to service by the end ofSLI-25 an update will be provided.

40 ML13284A058 L-2013-291 Repair RE-26-62 (NRC 10125113 10/17/13 WO 40268484 Closed 10/01/13 Commitment L-2013-291):

1907798-02 The detector is being repaired during SL 1-25 under WO 40268484.

No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

41 ML092990394 L-2009-217 When the Fitness for Duty Rule 12/26/15 Open 10/16/09 for Managing Fatigue is changed 00558580-0 I and an exemption from the requirements of I 0 CFR 26.205(c) and (d) for meeting work hour controls during declarations of severe weather conditions involving tropical storm or hurricane force winds is no longer needed, FPL will submit a letter to the NRC stating that the exemption is no longer needed.

42 MLI I 139Al67 L-2011-178 Revise License Renewal 02/15/16 Open This commitment is embedded 05/17/11 Documentation for new EPU in an RAI regarding the Unit I 01649522-0 I requirement EPU LAR and is not easily The fuel alignment plate, CEA identifiable.

shroud assemblies, and the upper guide structure support plate may be susceptible to irradiation embrittlement in addition to discussion of other degradation mechanisms in the LRA tables.

Cracking of these components was previously identified in the LRA. Irradiation embrittlement.

may result in decreases in fracture toughness of the fuel alignment plate, CEA shroud assemblies, and the upper guide structure support plate; FPL will update License Renewal documentation to reflect this change.

43 MLI 1287A039 L-2011-406 FPL commits to inform the NRC 01/29/21 Open This commitment was from an 10/12/11 about turbine disk inspection RAI response letter. The 01685035-01 results and plans to reduce the commitment is discussed in probability of turbine missile cover letter but is not provided generation, Pl, for continued as a separate section/table for No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

operation should cracks be tracking purposes. There was detected in the inspection no due date listed in letter.

44 MLl4051A608 L-2014-032 L-2014-032 contains one new 12/31/16 Open 02103114 01937510-0 I regulatory commitment in regards to committing to meeting the timeline in the NEI Open Phase Condition Initiative (Nuclear Energy Institute letter to the NRC, Industry Initiative on Open Phase Condition, dated October 9, 2013. (ML13333Al47)):

St. Lucie Nuclear Units I & 2 have committed to the generic schedule provided in the Industry NEI OPC Initiative, dated October 9, 2013.

451 MLl3088Al 73 L-2013-099 Item I:

12/10/15 Open 03/22/13 As stated in Enclosure 2 to MLl4070A097.

Updated by:

Updated by:

MLl4070A097 L-2014-056 02/24/14 01667266-23 461 L-2013-099 L-2013-099 Item 2:

12/10/15 Open ML13088Al 73 As stated in Attachment S of 03122113 01667266-24 MLl3088Al73.

471 MLl3088AI 73 L-2013-099 Item 3:

12/10/15 Open 03122113 As stated in Attachment S of 01667266-25 MLl3088Al73.

4g1 ML l 3088A 173 L-2013-099 Item 4:

12/10/15 Open 03122113 As stated in Attachment S of 0166 7266-21 MLl3088Al 73.

1 Regulatory Commitments 45 - 65 are related to the licensee's license amendment request regarding "'Transition to JO CFR 50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)" (ADAMS Accession No. ML13088Al 73). Commitment descriptions in source documentation contain security-related information. Pertinent publically available ADAMS Accession Nos. and dates are provided.

No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession andNAMS Description Date Date Documents No. and Tracking Reviewed Date No.

491 MLl3088AI 73 L-2013-099 Item 5:

I 0131113 I 0/19/13 Document detailing drawing Closed Drawings were included in the 03122113 As stated in Attachment S of revisions reviewed on-site.

reference documentation in 1667266-10 ML13088A173.

NAMS.

501 MLl3088AI 73 L-2013-099 Item 6:

9112113 09110113 Completion confirmed on-Closed 03122113 As stated in Attachment S of site.

1622516-04 MLl3088A173.

51 1 MLI 3088A 173 L-2013-099 Item 7:

12/10/15 Open 03122113 As stated in Attachment S of 01667266-26 MLl3088Al 73.

52 1 MLl3088Al 73 L-2013-099 Item 8:

12/10/15 Open 03122113 As stated in Attachment S of 0166 7266-22 MLl3088AI 73.

53 1 ML13088A173 L-2013-099 Item 9:

12110115 Open 03122113 As stated in Attachment S of 01667266-16 MLl3088A173.

54 1 MLl3088AI 73 L-2013-099 Item 10:

05/14/15 Open Original internal due date was 03/22/13 As stated in enclosure of not met. A revised due date 01667266-29 MLl5140A220.

NAMS was assigned to align with the ML15140A220 Date contractor schedule for 05/12/15 Revised:

NFPA-805 implementation.

03115116 In MLl5140A220, this commitment is listed with a statement that it will be completed no later than 12 months after NRC approval of the LAR. The revised due date falls within this timeframe.

55 1 ML13088Al73 L-2013-099 Item 11:

8/20/15 Open 03122113 As stated in Attachment S of 01667266-30 MLl3088A173.

561 MLl3088AI 73 L-2013-099 Item 12:

8/20/15 Open 03122113 As stated in Attachment S of 01667266-30 ML13088A173.

57 1 MLI 3088A 173 L-2013-099 Item 13:

12/10/15 Open 03/22/13 As stated in Attachment S of 01667266-12 MLl3088Al73.

No.

ADAMS FPL Ltr.

Commitment Due Completion Implementation Status Comments Accession and NAMS Description Date Date Documents No. and Tracking Reviewed Date No.

58 1 MLl3088Al 73 L-2013-099 Item 14:

08/13115 Open 03122113 As stated in Attachment S of 01667266-32 MLl3088A173.

59 1 MLl3088Al 73 L-2013-099 Item 15:

06/15/16 Open 03/22/13 As stated in Attachment S of 01876782-09 ML13088A173.

601 MLl3088Al 73 L-2013-099 Item16:

07/16/15 Open 03/22/13 As stated in Attachment S of 01667266-33 MLl3088A173.

61 1 ML13088A173 L-2013-099 Item 17:

08/13/15 Open 03122113 As stated in Attachment S of 01667266-34 MLl3088Al 73.

62 1 MLl3088A173 L-2013-099 Item 18:

08/13/15 Open 03122113 As stated in the Enclosure of MLl5140A220.

Updated by:

Updated by:

MLl4070A097 L-2014-056 02124114 Superseded by:

Superseded by:

MLl5140A220 L-2015-145 05112115 01667266-35 63 1 MLl4070A097 L-2014-056 Item 19:

08/13/15 Open 02124114 As stated in Enclosure 2 to 01667266-45 ML! 4070A097.

64 1 MLl5140A220 L-2015-145 Item 20:

09/15/18 Open 05112115 As stated in the Enclosure of 01876782-08 MLl5140A220.

65 1 ML! 3088A 173 L-2013-099 As stated in the Enclosure of 05101117 Open 03/22/13 MLl5140A220.

Superseded by:

Superseded by:

ML! 5140A220 L-2015-145 05112115 01876782-03

ML15215A494 OFFICE NRR/DORL/

NRR/DORL/

NRR/DORL/

LPL2-2/PM LPL2-2/PM LPL2-2/PM NAME CPfefferkorn FSaba BClayton DATE 08/07/15 08/0715 08/06/15