ML15288A472

Audit of the Licensee'S Management of Regulatory Commitments

ML15288A472
Person / Time
Site:	Robinson
Issue date:	12/16/2015
From:	Martha Barillas Plant Licensing Branch II
To:	Glover R Duke Energy Nuclear
Galvin D, NRR/DORL, 415-6256
References
CAC MF6425
Download: ML15288A472 (28)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 16, 2015 Mr. Richard M. Glover Site Vice President H. B. Robinson Steam Electric Plant Duke Energy 3581 West Entrance Road, RNPA01 Hartsville, SC 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (CAC NO. MF6425)

Dear Mr. Glover:

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.

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

An audit of the H. B. Robinson Steam Electric Plant Unit No. 2 (Robinson) commitment management program was performed at the plant site in Hartsville, South Carolina, during the period August 31, 2015, to September 3, 2015. The NRC staff concludes, based on the audit, and except as noted in the audit report, that: (1) Robinson has implemented NRC commitments on a timely basis, and (2) Robinson has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

The NRC staff notes that it is reviewing Robinson's change in a commitment to adopt Technical Specification Task Force Traveler-523, "Generic Letter-2008-01, Managing Gas Accumulation,"

as stated in letter dated October 14, 2014 (Agencywide Documents Access and Management System Accession No. ML14296A382), separately and will be communicating in separate correspondence regarding this commitment change.

R. Glover Please direct any inquiries to Dennis J. Galvin at 301-415-6256 or Dennis.Galvin@nrc.gov.

Sincerely, Martha Barillas, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

Audit Report cc w/enclosure: Distribution via Listserv

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 DOCKET NO. 50-261

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 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04 and confirm that regulatory commitments are being effectively implemented. An audit of the H. B. Robinson Steam Electric Plant Unit No. 2 (Robinson or HBRSEP) commitment management program was performed at the plant site in Hartsville, South Carolina, during the period August 31, 2015, to September 3, 2015. The audit reviewed commitments made since the previous audit on September 12, 2012.

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

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

2.1 Verification of Licensee's 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 Enclosure

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 (amendments, exemptions, etc.) or licensing activities (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 the Agencywide Document Access and Management System (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 The attached Audit Summary provides details of the audit and its results.

The NRC staff reviewed the relevant plant procedures to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC.

The NRC reviewed the two versions of the licensee's procedure that were in effect during the audit period: (1) REG-NGGC-0110, "Regulatory Commitment," Revision 4, which was the applicable procedure for most of the audit period, and (2) AD-LS-ALL-0010, "Commitment Management," which became effective February 12, 2015. In addition, the NRC staff reviewed a sample of open and closed commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation.

The NRC staff compared the guidance in procedure REG-NGGC-0110 to the guidance in NEI 99-04. As a result of this comparison, the NRC staff found that the procedure implemented

by the licensee is consistent with the NEI guidance for identifying, managing, and closing commitments. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in REG-NGGC-0110. The NRC staff performed a similar comparison of the guidance in procedure AD-LS-ALL-0010. The NRC staff had the following observations:

• AD-LS-ALL-0010 defines an ongoing commitment as "a regulatory commitment requiring continuing compliance. This includes any future or completed actions that must continually be adhered to." REG-NGGC-0110 included provision for managing ongoing commitments as defined in Section 9.8 but no corresponding provisions were included in AD-LS-ALL-0010. The licensee generated AR 1949626 to address this observation.

• REG-NGGC-0110, Section 9. 7 .6, and AD-LS-ALL-0010, Section 5.3.1, include provisions for the submittal of a commitment change summary report, but the licensee has not submitted this report. The licensee generated AR 1950400 to address this observation.

The licensee's commitments were tracked in a computer database called PassPort, which was replaced with a computer database called CAS in August 2015. Based on reports provided by the licensee CAS database during the audit, the NRC staff found that CAS is capable of providing the necessary information (e.g., summary of the commitment, commitment type, lead department, responsible individual, due date, extensions, closure method and date, and associated historical information) to manage NRC commitments. The NRC staff had several observations as listed below. Note that reports listed below with the designation starting with "AR" are documents in the licensee's CAS database.

• The licensee database CAS was recently implemented at the time of the onsite portion of the audit and did not have unique identifier for NRC commitments. The licensee recently created a second independent tracking system for NRC commitments in part to address this limitation in CAS. The second independent tracking system consists of a table in Microsoft Word. The NRC staff recommended that the licensee explore the capability of its nominal commitment tracking system, CAS, to uniquely identify NRC commitments.

• The NRC identified inconsistencies between CAS and the separate tracking system for NRC commitments.

o AR 583743 documents commitments in a letter dated May 14, 2013, which are associated with Generic Safety Issue GSl-191. AR 5837 43 documents one of these commitments, designated as Planned Action 3, as open. The licensee informed the NRC staff that this is the correct status. However, the separate tracking system for NRC commitments incorrectly states that Planned Action 3 is complete.

o AR 613091 documents a commitment in a letter dated June 24, 2013, which is associated with the repair of a pressurizer safety valve indication. The commitment provided an expected completion timeframe of prior to restart from the next refueling outage or during the first outage of sufficient duration.

AR 613091 indicates that the commitment was completed on November 8, 2013.

However, the separate tracking system for NRC commitments indicates that the commitment was completed on November 1, 2013. While the expected completion timeframe was met, the identification of different completion dates, potentially indicating unclear completion criteria, could result in future missed completion dates.

o AR 746629 documents a commitment in a letter dated May 13, 2015, which is associated with a license amendment request (LAR) to implement a new classification scheme for the Robinson emergency plan. The commitment is for Duke Energy to review the new classification scheme with state and local emergency management officials following NRC approval of the LAR and prior to implementation. The separate tracking system for NRC commitments did not include this commitment.

o In many cases, the closure documents listed in the separate tracking system for NRC commitments are either incorrect or are not listed. The NRC staff was able to verify the closure of the commitments during the audit by reviewing information in CAS. (The various commitment lists provided to the NRC prior to the audit were the licensee's separate tracking system for NRC commitments.)

o Clear criteria for the completion of a commitment is not currently in place, such as the need for the licensee licensing organization to close a commitment in CAS, in order to properly schedule and show clear closure of commitments.

• AR 539087 references a letter dated September 16, 2013, which is an LAR to adopt National Fire Protection Association (NFPA) 805 Performance-Based Standards.

Attachment "S" of the LAR contains 15 commitments to be implemented following NRC approval of the LAR. The LAR is still undergoing NRC review. The NRC staff identified that AR 539087 did not appear to actually track each of the 15 commitments. The licensee indicated that the items are being tracked but inconsistent with the commitment management procedures. The licensee generated AR 1950398 to address this observation.

The NRC staff reviewed site records associated with commitments involving generic letters, bulletins, and license amendments to determine whether the licensee had implemented the closed commitments appropriately, and whether the licensee had established a success path for future implementation of the open commitments.

The NRC staff reviewed the documentation associated with the closed regulatory commitments, particularly plant procedures that had been revised as a result of the commitments, and found that the commitments reviewed had been closed, with one exception in a manner that fully satisfied the commitments made to the NRC.

• AR 499929 documents a commitment in a letter dated February 10, 2012, which includes a LAR where the licensee committed to adopt TS Bases changes upon implementation of the license amendment. The NRC staff identified that actual

completion date for implementing the amendment and the commitment was beyond the implementation period identified in the license amendment. The licensee wrote AR 1950936 to address this. This observation was discussed with the resident office during the audit debrief.

Based on the sample of commitments reviewed, with the exceptions noted above, the NRC staff found that commitments tracked in accordance with the licensee's procedures, initially REG-NGGC-0110 and subsequently AD-LS-ALL-0010, were implemented satisfactorily. Also, based on the sample of licensee submittals and the NRC safety evaluations reviewed, the NRC staff found that commitments were tracked as specified by procedure REG-NGGC-0110 and AD-LS-ALL-0010. Additional details regarding the observations, as well as the summary of the overall results of the NRC staff review of the audit, are noted in the attached audit summary tables.

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at Robinson during the audit period is documented in the licensee's procedure REG-NGGC-0110 during the initial part of the audit period and AD-LS-ALL-0010 for the end of the audit period. The audit reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC.

2.2.1 Audit Results The attached Audit Summary also provides details of this portion of the audit and its results.

The NRC staff found that REG-NGGC-0110 and AD-LS-ALL-0010 adequately conform to the guidance and intent of NEI 99-04 for commitment tracking, the commitment change process, traceability of commitments, and reporting requirements, except as noted below. (This observation is also discussed in Section 2.1.2 above.)

• AD-LS-ALL-0010 defines an ongoing commitment as "a regulatory commitment requiring continuing compliance. This includes any future or completed actions that must continually be adhered to." REG-NGGC-0110 included provisions for managing ongoing commitments as defined in Section 9.8, but no corresponding provisions were included in AD-LS-ALL-0010. The licensee generated AR 1949626 to address this observation.

The NRG staff found that the licensee is adequately implementing the procedures and instructions for managing regulatory commitments in REG-NGGC-0110 and AD-LS-ALL-0010, which is consistent with the intent of NEI 99-04 guidelines pertaining to commitment changes, except as noted below (this observation is also discussed in Section 2.1.2 above).

• REG-NGGC-0110, Section 9.7.6, and AD-LS-ALL-0010, Section 5.3.1, include provisions for the submittal of a commitment change summary report, but the licensee has not submitted this report. The licensee generated AR 1950400 to address this observation.

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 included in the audit was 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 the commitments selected for the audit sample, all license amendment safety evaluations, exemptions, and relief request safety evaluations that have been issued for the facility 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.

3.0 CONCLUSION

The NRC staff concludes that, based on the above audit except as noted, (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. As further noted above, Robinson has initiated the applicable condition reports to address the staff observations.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Richard Hightower Manager - Nuclear Regulatory Affairs Scott Connelly Robinson Nuclear Plant Licensing Lead Engineer Heidi Walters Nuclear Regulatory Affairs - Administrative Support Principal Contributors: Martha Barillas Dennis J. Galvin Date: December 16, 2015 Attachments:

1. Summary of Audit Results

2. Misapplied Commitments September 13, 2012 - September 3, 2015

Summary of Regulatory Commitment Audit Results H.B. Robinson Steam Electric Plant Unit No. 2 Audit Period: September 13, 2012- September 3, 2015 Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents The licensee's 10/14/2014 letter states, "Based on the combined independent results of the Duke Energy's evaluation of TSTF-523 and the pilot prioritization project, Duke Energy will not submit a license amendment request (LAR) to adopt TSTF-523 for HBRSEP2."

Original Commitment: From Table 1 of Attachment II to RNP-RA/08-0099, 10/14/2008 AR 294794 further describes the basis for Item: 3 the change in the commitment to adoi;it Corrective Action: Submit a Technical Specification (TS) change request TSTF-523:

that proposes appropriate TS requirements for gas intrusion, including - The actions taken from GL 08-01 have applicable aspects of NRG-approved Technical Specification Task Force been effective in detecting and preventing (TSTF) generic changes to NUREG-1431. voids at Robinson.

Comi;iletion Date: Nine months following NRC approval of the TSTF 7/14/2014 - Given the already implemented actions, H.B. Robinson, Unit 2 - generic changes to NUREG-1431.

• Licensee changing the TS would have minimal impact Nine-Month Response RA-14-0016 on risk.

Licensee to NRC Generic Letter Revised Commitment: From Revised Regulatory Commitments table in ADAMS - Changing the TS will increase the RNP-RA/08-2008-01, "Managing attachment to RA-14-0016, 7/14/2014 ML14205A281 frequency of testing. This will negatively 0099 Initiated Gas Accumulation in Commitment: Complete the evaluation of TSTF-523 and submit a letter to impact personnel as they will be unavailable 10/14/2008 ADAMS or closed, Emergency Core the NRC providing a schedule for submittal of a License Amendment 10/14/2014 to perform other maintenance or operations ML082900579 Changed Cooling, Decay Heat Request. Licensee activities.

AR Removal, and Schedule: 10/15/2014 RNP-RA/14-294764 Containment Spray 0109 NRC staff resi;ionse to the commitment Systems." Revised Commitment: From page 2 of RNP-RA/14-0109, 10/14/2014 ADAMS change is under review.

Duke Energy will not submit a LAR to adopt TSTF-523 for H. B. Robinson ML14296A382 Steam Electric Plant Unit No. 2 (HBRSEP2). This constitutes a change in the regulatory commitment made by HBRSEP2.

• Note: The Notice of Availability for TSTF-523 was published in the Federal Register on 12/15/2014. See Federal Register dated 1/15/2014 (79 FR 2700), TSTF-523, "Generic Letter [GL] 2008-01, Managing Gas Accumulation," Using the Consolidated Line Item Improvement Process Attachment 1

Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents Commitment: From Cover page of RNP-RA/08-0124, 12/17/2008 A commitment is being made, in response to Request Number 25, 10/8/2010 pertaining to verification that plant conditions are bounded by the final Licensee WCAP-16793-NP and the final NRC Safety Evaluation (SE) when it is RNP-RA/10-H. B. Robinson, Unit 2 - issued. 0104 Response to Request ADAMS for Additional From page 28 of Attachment II of RNP-RA/08-0124, 12/17/2008 ML102860138 Licensee This commitment was open in the NRC Information re: NRC Master It will be verified that HBRSEP, Unit No. 2, plant conditions are bounded RNP-RA/08- 2012 Commitment Audit report. On Generic Letter 2004-02, List, by the final WCAP-16793-NP and the corresponding final NRC staff SE, 12/12/2012 0124 4/8/2013, the NRC staff issued the Safety "Potential Impact of Pending and by addressing the conditions and limitations in the final SE. Licensee 12/17/2008 ADAMS Evaluation for WCAP-16793-WP, Debris Blockage on in 2012 ML083570469 Revision 2. AR333711 documents that the Emergency Audit Closure: The licensee lists this commitment as closed based on ADAMS AR commitment was completed on 5/20/2013.

Recirculation During Report RNP-RA/10-0104, ML102860138, 10/8/2010, which is a supplemental ML12342A016 333711 The NRC staff had no observations.

Design Basis Accidents RAI response. RNP-RA/10-0104 does not mention WCAP-16793-NP, at Pressurized-Water which is the subject of the commitment. 4/8/2013 Reactors". Licensee NRC 2012 Audit: From the audit report, page 2 ofTable: List of Commitments Included in the Audit, 12/17/2012(ML12342A016) ADAMS The commitment is being tracked in PassPort and has been given an ML13084A161 aoorooriate due date consistent with the intenUscooe of GL-2004-02.

Commitment: From Enclosure 2 of RA-11-019, 6/29/2011 Brunswick, Units 1 & 2, New Regulatory Commitment: HBRSEP, Unit No. 2 will submit an LAR Crystal River, Unit 3, for transitioning to NFPA 805. The LAR will include a plant-wide and H. B. Robinson, assessment to identify fire areas and fire hazards and evaluate Licensee 9/16/2013 Unit 2, Request for compliance with the existing HBRSEP, Unit No. 2 fire protection licensing RA-11-019 Licensee As the NFPA 805 LAR was submitted on Extension of basis. This assessment will be performed in accordance with NEI 04-02, ADAMS Initiated RNP-RA/13- 9/16/2013, this met the commitment to 06/29/2011 Enforcement Discretion "Guidance for Implementing a Risk-Informed, Performance-Based Fire ML11188A058 or closed. 0090 submit the LAR by 9/30/2013. The NRC and Commitment to Protection Program under 10 CFR [Title 1O of the Code of Federal AR ADAMS staff had no observations.

Submittal Dates for Regulations] 50.48(c)."

ML13267A211 10 CFR 50.48(c) Due Date: 9/30/2013 License Amendment Requests. Closure: Closed 9/16/13 NFPA 805 LAR Submitted via letter RNP-RA/13-0090, ML13267A211 Licensee Commitment: From Cover page of RNP-RA/11-0029, 8/10/2011 9/26/2012 H. B. Robinson, Unit 2 - RNP-RA/11-Carolina Power & Light (CP&L) commits to submit a new Aging Licensee The NRC staff reviewed AR 483656 and Withdrawal of Reactor 0029 Initiated Management Program no later than 10/1 /2012. RNP-RA/12- verified that the action is tracked as 08/1012011 Vessel Internals Aging ADAMS or closed. 0100 complete. The NRC staff had no Management Program ML11228A027 Closure: Closed 9/26/12 via RNP-RA/12-0100 ML12278A398 ADAMS observations.

Inspection Plan. AR ML12278A398 483656 2

Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents Commitment: From Attachment IV of RNP-RA/11-0095, 2/10/2012 .

CP&L will adopt the Technical Specification Bases changes as shown in AR 499929 indicates that TS Bases and the Attachment V upon implementation of this license amendment.

TS surveillance requirements were revised H. B. Robinson, Unit 2, Licensee on 12/26/2012.

Master Closure: Closed 2/10/12 via RNP-RA/11-0095 Request for Technical RNP-RA/11- 7/6/2012 List, Specifications Change 0095 Licensee NRC Staff Observations Pending NRC 2012 Audit: The commitment is being tracked in PassPort and has 02/10/2012 Regarding Missed ADAMS The 12/26/2012 completion is beyond the in 2012 been given an appropriate due date consistent with the intent/scope of Surveillance Using the ML12059A127 ADAMS 120 day implementation period identified in Audit the LAR.

Consolidated Line Item AR ML12160A409 the amendment. This condition was Report Improvement Process. 499929 discussed with the Robinson resident Office.

Note: The LAR submittal, which contains the original commitment, is not The licensee wrote AR 1950936 to address an appropriate closure document. Also, the license amendment.was the condition.

issued on 7/6/2012(ML12160A409) with a 120 day implementation Jperiod.

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Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents Commitment: From Enclosure 1 of RA-12-022, 5/9/2012 The Progress Energy commitments were completion dates to submit responses to for 3 requests regarding communications and 6 requests regarding staffing. For brevity, the request texts are omitted.

Communications:

Request 1: 10/3112012 Request 2: 6/11/2012 Request 3: 10/31/2012 Staffing:

Request 1: Four months prior to beginning of second refueling cycle following submittal of overall integrated plan required by Order EA 5/2/2013 Carolina Power & Light 049,Section IV.C .. a or four months prior to 12/31/2016, whichever Licensee Company and Florida comes first.

RRA-13-0032 The NRC staff commitment audit focused on Power Corporation's Licensee Request 2.1: Seven months prior to beginning of second refueling cycle ADAMS other commitments consistent with NRR 60-Day Response to RA-12-022 following submittal of overall integrated plan required by Order EA ML13105A413 Office Instruction LIC-105, Revision 5. Thus the March 12, 2012, ADAMS Initiated 049,Section IV.C .. a or four months prior to 12/31/2016, whichever 05/09/2012 the supporting documents associated with Request for Information ML12138A016 or closed. comes first.

5/12/2015 these commitments were not reviewed Regarding Enclosure 5, AR Request 2.2: Four months prior to beginning of second refueling cycle Licensee during the onsite portion of the commitment Recommendation 9.3: following submittal of overall integrated plan required by Order EA RRA-15-0040 audit. The NRC staff had no observations.

Emergency 049,Section IV.C .. a or four months prior to 12/31/2016, whichever ADAMS Preparedness. comes first.

ML15124A523 Request 3: 6/11/2012 Request 4: 6/11/2012 Request 5: 6/11/2012 Request 6: Four months prior to beginning of second refueling cycle following submittal of overall integrated plan required by Order EA 049,Section IV.C.. a or four months prior to 12/31/2016, whichever comes first.

Closure: Closed 5/2/13 Via RRA-13-0032 ML13105A413; Closed 5/12/15 Via RRA-15-0040 ML15124A523 Note: The closure documents listed are NRC assessment of licensee submittals, not actual licensee submittals.

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Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents Commitment: From Attachment Vof RA-12-0033, 8/6/2012 Regulatory Commitments: Progress Energy will establish the Technical H. 8. Robinson Steam Specification Bases for LCO 3.0.8 as adopted with the applicable license Electric Plant, Unit Licensee amendment. The NRC staff reviewed AR 551391 and No. 2, Application for RNP-RA/12- 2/26/2013 verified that the action is tracked as Technical Specification 0033 Due Date/Event: Will be completed at the time of implementation of the Licensee complete. AR 551391 shows a completion Change to Add LCO Initiated 08/06/2012 ADAMS approved amendment. RRA-13-0013 date of 4/11/2015, which is within the 3.0.8 on the or closed.

ML12229A047 ADAMS 60-day implementation period specified in lnoperability of AR Closure: Closed 2/26/13 Via RRA-13-0013ML13017A381 ML13017A381 the amendment. The NRC staff had no Snubbers Using the 551391 observations.

Consolidated Line Item Note: The closure document listed is the issued license amendment, not Improvement Process.

a licensee document implementing the license amendment. The issued license amendment had an implementation period of 60 days.

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Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents Commitment: From page 2 of RA-12-0101, 10/5/2012 This letter contains the following Regulatory Commitments:

1. The valve will be shielded from environmental elements with access for inspection until a Code Repair/Replacement.

2. Until installation of a clamp or until a Code Repair/Replacement is performed:

a. Operations personnel will visually monitor the leak each shift with results entered into AUTOLOG. A crack length greater than 1 inch or a leakage increase greater than 16 drops/minute will require station management attention and entered into the Corrective Action Program for appropriate evaluation and further actions.

H. B. Robinson Steam b. Nondestructive Examination personnel will perform ultrasonic Electric Plant, Unit 2, volumetric examination of the flaw location every 90 days. A crack length Relief Request (RR)-7 greater than 7 inches will require station management attention and from Immediate Licensee entered into the Corrective Action Program for appropriate evaluation and American Society of RNP-RA/12- further actions.

AR 564771 and 564801 indicate that the Mechanical Engineers 0101 3. Following installation of a clamp:

valve was replaced and identified the (ASME) Code Repair of ADAMS Initiated a. A system leakage test at normal operating pressure and normal 10/05/2012 appropriate work orders consistent with the Refueling Water ML12292A386 or closed. operating temperature and a VT-2 examination in accordance with 4th commitment in RA-12-0101. The NRC Storage Tank Drain AR IWA-5000 will be performed on the portion of line number 6-Sl-151 R-staff had no observations.

Valve (Sl-837) for Fifth 564771 141 containing the clamp.

Ten-year lnservice 564801 b. The area around the clamped valve will be monitored for leakage on a Inspection Program weekly basis in accordance with Article IX-6000 (c) with a record entered Plan. into AUTOLOG and with an entry made into the Corrective Action Program for appropriate evaluation and disposition in the event leakage is observed.

4. An ASME Section XI Code Repair/Replacement shall be performed during the next scheduled refueling outage, R0-28, which is currently scheduled to begin September 2013. If a condition leads to a forced outage of sufficient duration and scope to allow a Code Repair/Replacement, the repair will be performed during this forced outage.

Closure: Closed 10/20/13 Note: A closure date is identified but no closure documents.

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Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents Commitment: From Page 2 of RA-12-0128, 11/27/2012 This document contains the following Regulatory Commitment:

An updated report with the results of restricted access inspections for the entries in the Table below will be submitted by 2/28/2014.

H. B. Robinson, Unit 2 -

Feature Inspection Date Response to Licensee The NRC staff commitment audit focused on AFW MOPS TO SG-B SQUARE 2/28/2014 2/27/2014 Recommendation 2.3 RNP-RA/12- other commitments consistent with NRR 480 V EMERGENCY BUS E1 2/28/2014 Licensee "Seismic Walkdown" of 0128 Office Instruction LIC-105, Revision 5. Thus Initiated HAGAN RACK 30 2/28/2014 RNP-RA/14-11/27/2012 the Near-Term Task ADAMS the supporting documents associated with or closed. HAGAN RACKS 1-13, 26 2/28/2014 0011 Force Review of ML123410131 these commitments were nor reviewed INVERTER-A 2/28/2014 ADAMS Insights from the AR during the onsite portion of the commitment ML14069A151 Fukushima Dai-lchi audit. The NRC staff had no observations.

Closure: Closed 2/27/14 Via RNP-RA/14-0011 ML14069A151 Accident Note: ML14069A151 is H. B. Robinson, Unit 2, Revision to Response to Recommendation 2.3 "Seismic Walkdown" of the Near-Term Task Force Review of lnsiohts from the Fukushima Dai-lchi Accident.

Commitment: From the attachment to RA-12-001 01/29/2013 Commitment: H. B. Robinson Steam Electric Plant'. Unit No. 2:

If an integrated assessment is triggered based on the guidance in the Brunswick, Units 1 & 2, NRC .L.etter from D. L. Skeen (NRC) to J.E. Pollock (NEI), Trigger Crystal River, Unit 3, Cond1t1ons for Performing an Integrated Assessment and Due Date for Shearon Harris, Unit 1, Response, dated 12/3/2012, Accession No. ML12326A912 CP&L will H. B. Robinson, Unit 2, utilize th.e guidance contained in JLD-ISG-2012-05, Guidan'ce for Carolina Power & Light Pe~orming the.Integrated Assessment for External Flooding, Interim Staff Company's and Florida Licensee Guidance, Rev1s1on 0, dated 11/30/2012, Accession No. ML12311A214, This commitment is open. The NRC staff Power Corporation's RA-12-001 Open, to perform the assessment. confirmed that AR 674387 includes a due Response to the March ADAMS 01/29/2013 Initiated Scheduled Completion Date*: March 12, 2016 date of 3/12/2016 to complete the 12, 2012, Request for ML13032A071 or closed. scheduled commitment. The NRC staff had Information, Enclosure AR

• Scheduled completion dates are consistent with the Integrated no observations.

2, Recommendation 674387 Assessment completion date as specified in Reference 1 based on the 2.1, Flooding, site priorities specified in NRC letter, "Prioritization of Response Due Required Response 1, Dates for Request for Information Pursuant to Title 1O of the Code of Integrated Assessment Federal Regulations 50.54(f) Regarding Flooding Hazard Reevaluations Approach for RecommendaUon 2.1 of the Near-Term Task Force Review of Insights From the Fukushima Dai-lchi Accident," dated 5/11/2012.

Onen: Due 3/12/2016 7

Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents H. B. Robinson, Unit 2, Commitment: From cover page of RNP-RN13-0017, 03/06/2013 Response to Request Submit a revised license amendment request regarding Steam Generator for Additional Licensee program inspection frequencies and tube sample selection, and Information for Review 4/9/2013 RNP-RN13- application of permanent alternate repair criteria (H*), by 4/10/2013.

Regarding Steam Licensee 0017 The NRC staff confirmed that the licensee Generator License Initiated RNP-RN13-03/06/2013 ADAMS Closure: Closed 4/9/13 Via RNP-RN13-0030 ML13123A221 submitted the letter. The NRC staff had no Amendment Request to or closed. 0030 ML13072A300 observations.

Revise Technical ADAMS AR Note: ML13123A221 is H.B. Robinson Steam Electric Plant, Unit 2, Specifications for ML13123A221 593069 Revision to License Amendment Request for Revision to Steam Steam Generator Generator Program Inspection Frequencies and Tube Sample Section Permanent Alternate and Application of Permanent Alternate Repair Criteria.

Reoair Criteria.

Commitment: From the attachment to RNP-RN13-0048, 5/14/2013 Planned Action 1: HBRSEP Unit No. 2 will complete measurements for The NRC staff identified several observation insulation replacement. related to AR 583743.

Date: 5/31/2015 - Planned Action 1: The NRC staff Closure: Complete 4/15/2015 confirmed that AR 583743 documents the completion of planned action 1 on Planned Action 2: HBRSEP Unit No. 2 will complete any necessary 4/15/2015.

Licensee insulation replacements or remediation, or other identified plant changes. - Planned Action 2: Following the onsite RNP-RN13-H. B. Robinson Steam Date: May31, 2018 portion of the audit, the licensee explained 0048 Open, Electric Plant, Unit 2, Open: that the actions will be completed during a 05/14/2013 ADAMS Initiated Path Forward for spring 2017 refueling outage, which is prior ML13141A283 or closed.

Resolution of GSl-191. Planned Action 3: HBRSEP Unit No. 2 will submit a final updated to the May 2018 commitment. AR 583743 AR supplemental response to support closure of GL 2004-02. will be updated to reflect this time frame.

583743 Date: Within 6 months of receipt of the SE for the risk-informed resolution - Planned Action 3: AR 583743 correctly licensing action. shows that planned action 3 is not complete Closure: Complete 5/15/2013 while the separate tracking system states that it is complete. This observation is covered by general observations on the Note: Regarding planned action 3, there is no document in ADAMS, tracking system.

dated 5/15/2013, on the Robinson docket related to GL 2004-02.

The NRC staff identified an observation related to AR 613091.

H.B. Robinson, Unit 2, Commitment: From cover page of RNP-RN13-0066, 6/24/2013 Licensee -The NRC staff confirmed thatAR 613091 Technical This letter contains exactly one (1) new commitment. It is committed that RNP-RN13- 11/1/2013 states that the activity to close the Specifications Section RC-551A pressurizer safety valve position monitor will be repaired and 0066 Licensee commitment was completed by 5.6.6 Post Accident Initiated the repair is expected to be completed prior to restart from the next 06/24/2013 ADAMS WO 02253506 WO 02253506.

Monitoring or closed. refueling outage, which is currently scheduled to begin on 9/14/2013, or ML13189A141 ADAMS - AR 613091 was closed on 11/8/2013 while Instrumentation Report during the first outage of sufficient duration.

AR the tracking system shows a completion for the Pressurizer 613091 date of 11/1/2013. This observation is Safety Valve Indication. Closure: Closed Completed 11/1/2013 via WO 02253506 covered by general observations on the tracking system.

8

Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents Commitment: From Enclosure 1 of RA-13-012, 06/26/2013 Commitment: Brunswick, Shearon Harris, and H. B. Robinson will compile design data supporting modeling with a multi-source/multiple Brunswick, Units 1 & 2, release pathway software code such as Raddose V or The NRC staff confinmed that AR 610491 Licensee Crystal River, Unit 3, multi-source/multiple release point modeling capable version of Unified documents the development of the relevant RA-13-012 Shearon Harris, Unit 1, Initiated RASCAL Interface (URI), test the new program, develop relevant procedures and the completion of training ADAMS 06/26/2013 and H. B. Robinson, or procedures, perfonm training, and complete implementation by on the software. The actions were ML13190A313 Unit 2, Capability to closed. 12/31/2014. completed by 12/15/2014, which meets the AR Perfonm Multi-Unit Dose Scheduled Completion Date: 12/31/2014 12/31/2014 commitment date. The NRC 610491 Assessment. staff had no observations.

Closure: Closed Complete 12/31/2014 Note: A closure date is identified but no closure documents.

H.B. Robinson Steam Commitment: From Enclosure 2 of RA-13-090, 09/16/2013 Electric Plant Licensee The NRC staff identified an observation Regulatory Commitments: HBRSEP Unit No. 2 will complete those (HBRSEP), Unit 2, RNP-RA/13- related to AR 539087.

modifications and implementation items outlined in Attachment 'S' to this License Amendment 0090 - The NRC staff was unable to identify how letter.

Request (LAR) to Adopt ADAMS AR 539087 was tracking the completion of Open, Date: Prior to startup after completion of HBRSEP Unit No. 2 Refueling NFPA 805 ML13267A211 the 15 commitments in Attachment "S" of 09/16/2013 Initiated Outage 31, currently scheduled to begin in the spring of 2018.

Performance-Based ML13267A212 the LAR. The licensee indicated that the or closed.

Standard for fire (Enclosure 2, items are being tracked but are inconsistent Open: See due date.

Protection for Light Non-public) with the commitment management water Reactor AR procedures. The licensee generated Note: Attachment "S" list 15 items. However, Attachment "S" is not Generating Plant 539087 AR 1950398 to address this observation.

available to the public due to security-related information.

(2001 Edition).

Commitment: From Enclosure 2 of RNP-RA/14-0012, 03/12/2014 Enclosure 2 includes a table with 3 item that summarizes interim actions taken or planned and their respective completion dates.

H. B. Robinson Steam Electric Plant, Unit No.

Item 1 is associated with the initiating event Localized Intense 2 - Flood Hazard Precipitation (LIP). 4 interim actions are identified. The first 3 interim Reevaluation Report, actions have implementation dates of 3/12/2014. The 4th interim action Response to NRC 10 has an implementation date of prior to entering MODE 4 during plant CFR 50.54(t) Request Licensee restart from the current maintenance outage (R229F3).

for lnfonmation RNP-RA/14-Pursuant to Title 1O of 0012 Open, Item 2 is associated with the initiating event Probable Maximum Flood The NRC staff verified that AR 674387 the Code of Federal 03/12/2014 ADAMS Initiated (PMF). 5 interim actions are identified. The first 4 interim actions have documents the completion of Items 1 and 2.

Regulations 50.54(f)

ML14086A384 or closed. implementation dates of 3/12/2014. The 5th interim action has an The NRC staff had no observations.

regarding AR implementation date of prior to entering MODE 4 during plant restart from Recommendations 2.1, 674387 the current maintenance outage (R229F3).

2.3 and 9.3 of the Near-Term Task Force Item 3 is A Flooding Integrated Assessment will be completed and report Review of Insights from submitted to the NRC on or before 3/12/2016.

the Fukushima Dai-ichi Accident, Dated Open:

March 12, 2012 Note: The implementation dates for Items 1 and 2 are past and closure is not indicated and no closure documents are identified.

9

Document Document Related Document Title Duke List Commitment(s)* Completion Notes Date Numbers Documents The NRC staff identified an observation Licensee Commitment: From Enclosure 2 of RNP-RA/15-0034, 05/13/2015 Duke related to AR 746629.

RNP-RA/15- Energy commits to review the new classification scheme with state and - The NRC staff confirmed that AR 746629 Not on H. B. Robinson, Unit 2 - 0034 local emergency management officials following NRC approval and prior documents the actions associated with the any Duke 05/13/2015 Proposed Changes to ADAMS to implementation. commitment. However, this commitment Energy Emergency Plan. ML15133A452 was not included in the licensee's tracking List AR Open: system. This observation is covered by 746629 general observations on the tracking system.

• The Commitments in the "Commitment(s)" column are based on the licensee submittals. The "Closure" statements listed in the "Commitment(s)" column are taken from the various commitment lists provided to the NRC prior to the audit, which are essentially from the licensee's separate tracking system for NRC commitments. In many cases the closure documents listed are either incorrect or are not listed, as noted. The NRC staff was able to verify the closure of the commitments during the audit by reviewing information in CAS.

10

Regulatory Commitment Audit: Review of Amendments. Relief Requests, and Exemptions for Misapplied Commitments H. 8. Robinson Steam Electric Plant Unit No. 2 Audit Period: September 13, 2012 - September 3, 2015 NRG Staff Licensee Document Document NRG Staff Document Title Licensee Staff Document Title Completion Notes Information Information The licensee 9/12/2012 submittal refers to the cyber security plan implementation schedule as a regulatory commitment.

The licensee identified that a change to the regulatory commitment is identified in Attachment 3.

The NRG raised the regulatory commitments for the cyber security plan to obligations by means of a license condition:

The license condition in Paragraph 3.F of Renewed Operating License No. DPR-23 for HBRSEP, is modified as follows:

Date

'The licensee shall fully implement and maintain in effect 12/18/2012 Date Brunswick, Units 1 and 2; H. B. all provisions of the Commission-approved cyber security Amendment 09/12/2012 Carolina Power & Light Company and Florida Robinson, Unit 2; Shearon Harris, Unit 1; plan (CSP), including changes made pursuant to the 230 Licensee Power Corporation's License Amendment and Crystal River, Unit 3 - Issuance of authority of 10 CFR 50.90 and 10 CFR 50.54(p). The ADAMS RA-12-031 Request - Cyber Security Plan Implementation License Amendments Regarding Cyber licensee's CSP was approved by License Amendment ML12339A067 ADAMS Schedule Milestones.

Security. No. 226, as supplemented by a change approved by TAC ML12268A055 license Amendment No. 230."

ME9549 Therefore the safety evaluation properly states:

The NRG staff does not regard the CSP milestone implementation dates as regulatory commitments that can be changed unilaterally by the licensee, particularly in light of the regulatory requirement at 10 CFR 73.54, that

"[i]mplementation of the licensee's cyber security program must be consistent with the approved schedule."

Therefore, amendment 230 does not contain any misapplied commitments.

Attachment 2

NRC Staff Licensee Document Document NRC Staff Document Title Licensee Staff Document Title Completion Notes Information Information H. 8. Robinson, Unit 2 - Request for Technical In the 3/16/2012 submittal, the licensee states that there are Date Specifications Change Regarding Corrections no commitments made in this submittal. In the 8/16/2012 02/13/13 Date to Table 3.3.1-1 Note 1. submittal, the licensee states that this document contains no H. 8. Robinson Steam Electric Plant, Amendment 03/16/2012 new Regulatory Commitments.

Unit 2 - Issuance of an Amendment 231 Licensee Supplements:

Request for Technical Specifications ADAMS RNP-RA/12-0009 08/16/2012, RNP-RA/12-0085, ML12242A242 The NRC issuance of the amendment has no discussion of Change Regarding Corrections to ML13014A641 ADAMS H. 8. Robinson, Unit 2, Response to NRC regulatory commitments.

Table 3.3.1 Note (TAC No. ME8225).

TAC ML12083A292 Request for Additional Information Related to ME8225 Technical Specification Change Regarding Therefore, amendment 231 does not contain any misapplied Corrections to Table 3.3.1-1 Note 1. commitments.

The licensee's 8/6/2012 submittal states that it contains one new Regulatory Commitment listed in Attachment 5.

The commitment is that Progress Energy will establish the Technical Specification Bases for LCO 3.0.8 as adopted with Date the applicable license amendment.

H. B. Robinson Steam Electric Plant, 02/26/13 Date Unit 2 - Issuance of Amendments Re: H. 8. Robinson Steam Electric Plant, Unit Amendment 08/06/2012 The due date is that the commitment will be completed at the Technical Specification Change to Add No. 2, Application for Technical Specification 232 Licensee time of implementation of the approved amendment.

Limiting Condition of Operation 3.0.8 on Change to Add LCO 3.0.8 on the lnoperability ADAMS RNP-RA/12-0033 the lnoperability of Snubbers Using the of Snubbers Using the Consolidated Line Item ML13017A381 ADAMS The NRC staff SE discusses the TS bases for LCO 3.0.8. as Consolidated Line Item Improvement Improvement Process.

TAC ML12229A047 part of the review as the TS bases were discussed in the Process (TAC No. ME9236).

ME9236 NRC staff approval of the associated TSTF- 372. The NRC issuance of the amendment has no specific discussion of the regulatory commitment Therefore, amendment 232 does not contain any misapplied commitments.

2

NRG Staff Licensee Document Document NRG Staff Document Title Licensee Staff Document Title Completion Notes Information Information H. B. Robinson, Unit 2 - Request for Technical Specification Changes Regarding TS 3.1.4 Rod Group Alignment Limits and TS 3.1. 7 Rod Position Indication.

In the Enclosure to the 6/8/2012 letter, the licensee indicates Supplements: that Attachment 4 includes a list of Regulatory Commitments.

10/12/2012, RNP-RA/12-0108, ML12298A359 However, no attachment 4 was docketed.

H. B. Robinson, Unit 2 - Replacement Enclosure Cover Page for Request for The 10/12/2012 licensee submittal indicated that there was Technical Specification (TS) Changes only three attachments to the enclosure and provided a Date H. B. Robinson Steam Electric Plant, Regarding TS 3.1.4 Rod Group Alignment correction page.

05/16/13 Date Unit 2 - Issuance of an Amendment on Limits and TS 3.1. 7 Rod Position Indication.

Amendment 06/08/2012 Technical Specification Changes The 10/22/2012 licensee submittal states that this document 233 Licensee Regarding an Additional of a Note to 10/22/2012, RNP-RA/12-0107, ML12310A085 contains no new Regulatory Commitments.

ADAMS RNP-RA/12-0028 Limiting Conditions for Operation 3.1.4 H. B. Robinson, Unit 2 - Response to Request ML13101A369 ADAMS and 3.1. 7 Allowing 1-Hour Soak Time for Additional Information Related to Changes The 4/24/2013 licensee submittal states that this document TAC ML12172A260 (TAC No. ME8844). Regarding Technical Specification (TS) 3.1.4 contains no new Regulatory Commitments.

ME8844 Rod Group Alignment Limits and TS 3.1. 7 Rod Position Indication. The NRG issuance of the amendment has no discussion of regulatory commitments.

04/24/2013, RNP-RA/13-0038, ML13128A072 H. B. Robinson Steam Electric Plant, Unit No. 2 Therefore, amendment 233 does not contain any misapplied

- Replacement of Technical Specification commitments.

Pages to Correct Typographical Errors in Request for TS Changes Regarding TS 3.1.4 Rod Group Alignment Limits and TS 3.1. 7 Rod Position Indication.

H. B. Robinson Steam Electric Plant, Unit 2 -

License Amendment Request to Delete Technical Specification Reactor Protection The 9/6/2012 licensee submittal states that this letter System Trip on Steam Generator Water Level contains no new Regulatory Commitments.

Date H. B. Robinson Steam Electric Plant, Low Coincident with Steam Flow/Feedwater 05/29/13 Unit 2 - Issuance of an Amendment to Date Flow Mismatch. The 12/7/2012 licensee submittal states that this letter Amendment Eliminate Steam Generator Water Level- 09/06/2012 contains no new Regulatory Commitments.

234 Low Coincident with Steam Licensee Supplements:

ADAMS Flow/Feedwater Flow Mismatch Function RNP-RA/12-0095 12/07/2012, RNP-RA/12-0115, ML12361A015 The NRC issuance of the amendment has no discussion of ML13114A714 from TS Table 3.1.1-1. Reactor ADAMS H. B. Robinson, Unit 2, Response to Request regulatory commitments.

TAC Protection System Instrumentation ML12263A424 for Additional Information for Review Regarding ME9516 (TAC No. ME9516).

Deletion of the Reactor Trip on Steam Therefore, amendment 234 does not contain any misapplied Generator Water Level Low Coincident with commitments.

Steam Flow/Feedwater Flow Mismatch from the Technical Specifications.

3

NRC Staff Licensee Document Document NRC Staff Document Title Licensee Staff Document Title Completion Notes Information Information H. B. Robinson, Unit 2 - License Amendment Request for Revision to Steam Generator The 8/29/2012 licensee submittal states that this letter Program Inspection Frequencies and Tube contains no new Regulatory Commitments. The submittal Sample Selection and Application of describes how commitments from amendment 224 are Permanent Alternate Repair Criteria (H*).

addressed by TSs 5.5.9 and 5.6.8.

Supplements:

The 3/6/2013 licensee submittal contained one new 03/06/2013, RNP-RA/13-0017, ML13072A300 regulatory commitment.

H. B. Robinson, Unit 2, Response to Request for Additional Information for Review Regarding Submit a revised license amendment request regarding Steam Generator License Amendment Request Date Steam Generator program inspection frequencies and H. B. Robinson Steam Electric Plant, to Revise Technical Specifications for Steam 08/29/13 Date tube sample selection, and application of permanent Unit 2 - Issuance of an Amendment to Generator Permanent Alternate Repair Criteria.

Amendment 08/29/2012 alternate repair criteria (H*), by April 10, 2013.

Revise the Steam Generator Program 235 Licensee Inspection Frequencies and Tube 04/09/2013, RNP-RA/13-0030, ML13123A221 ADAMS RNP-RA/12-0057 The 4/9/2013 licensee submittal states that this document Sample Selection and Application of H. B. Robinson Steam Electric Plant, Unit 2, ML13198A367 ADAMS contains no new Regulatory Commitments. The submittal Permanent Alternate Repair Criteria (H*) Revision to License Amendment Request for TAC ML12251A363 describes how commitments from amendment 224 are (TAC No. ME9448). Revision to Steam Generator Program ME9448 addressed by TSs 5.5.9 and 5.6.8.

Inspection Frequencies and Tube Sample Section and Application of Permanent Alternate The 8/22/2013 licensee submittal states that this document Repair Criteria.

contains no new Regulatory Commitments.

08/22/2013, RNP-RA/13-0089, ML13249A028 The NRG SE describes how commitments from amendment H. B. Robinson Steam Electric Plant, Unit No. 2 224 are addressed by TSs 5.5.9 and 5.6.8.

- Replacement of Technical Specification Pages to Correct Typographical Errors in Therefore, amendment 235 does not contain any misapplied Request for TS Changes Regarding TS 3.1.4 commitments.

Rod Group Alignment Limits and TS 3.1. 7 Rod Position Indication.

Date The licensee's 4/20/2013 submittal states that this document 10/21/13 Date contains no regulatory commitments.

Brunswick Steam Electric Plant, Units 1 Amendment 04/20/2013 and 2; Shearon Harris Nuclear Power License Amendment Request to Facility 236 Licensee The NRG issuance of the amendment has no discussion of Plant, Unit 1; and H. 8. Robinson Steam Operating Licenses for Change of Licensee ADAMS BSEP 13-0013 regulatory commitments related to Robinson.

Electric Plant, Unit 2 - Name Change Name.

ML13267A293 ADAMS (TAC Nos. MF1463-MF1466).

TAC ML13155A492 Therefore, amendment 236 does not contain any misapplied MF1466 commitments.

4

NRC Staff Licensee Document Document NRC Staff Document Title Licensee Staff Document Title Completion Notes Information Information H. B. Robinson, Unit 2 - License Amendment Request for Technical Specification(TS) In the 9/30/2013 submittal, the licensee states that this letter Change to Use NRC-Approved TSTF-491, contains no new Regulatory Commitments.

Date Revision 2, Removal of Main Steam and Main 10/10/14 H. B. Robinson Steam Electric Plant, Date Feedwater Valve Isolation Times from In the 8/6/2014 submittal, the licensee states that this Amendment Unit 2 - Issuance of an Amendment on 09/30/2013 Technical Specifications. document contains no new Regulatory Commitments.

237 Adoption of TSTF-491, "Removal of Main Licensee ADAMS Steam and Main Feedwater Valve RNP-RA/13-0077 Supplements: The NRC issuance of the amendment has no discussion of ML14252A221 Isolation Times From Technical ADAMS 08/06/2014, RNP-RA/12-0085, ML14231A896 regulatory commitments.

TAC Specifications" (TAC No. MF2838). ML13283A012 H. B. Robinson, Unit 2, Response to NRC MF2838 Request for Additional Information Related to Therefore, amendment 237 does not contain any misapplied Technical Specification Change Regarding commitments.

Corrections to Table 3.3.1-1 Note 1.

H. B Robinson Steam Electric Plant, Unit 2 - In the 9/10/2013 submittal, the licensee states that this letter License Amendment Request to Modify contains no new Regulatory Commitments.

Date Technical Specification 3.4.12, Low 10/15/14 H. B. Robinson Steam Electric Plant, Date Temperature Overpressure Protection System. In the 4/8/2014 submittal, the licensee states that this letter Amendment Unit 2 - Issuance of Amendment 09/10/2013 contains no new Regulatory Commitments and no revision to 238 Regarding Technical Specification 3.4.12 Licensee Supplements: existing Regulatory Commitments.

ADAMS Change for the Low Temperature RNP-RA/13-0067 04/08/2014, RNP-RA/14-0037, ML14106A370 ML14260A380 Overpressure Protection (LTOP) System ADAMS H. B. Robinson, Unit 2 - Response to NRC The NRC issuance of the amendment has no discussion of TAC (TAC No. MF2718). ML13262A008 Request for Additional Information Regarding regulatory commitments.

MF2718 License Amendment Request to Modify Technical Specification 3.4.12, Low Therefore, amendment 238 does not contain any misapplied Temperature Overpressure Protection Svstem. commitments.

H. B. Robinson Steam Electric Plant, Unit 2 - In the 9/10/2013 submittal, the licensee states that this letter License Amendment Request to Modify contains no new Regulatory Commitments.

Date Technical Specification 3.4.12, Low 12/19/14 H. B. Robinson Steam Electric Plant, Date Temperature Overpressure Protection System. In the 4/8/2013 submittal, the licensee states that his Amendment Unit 2 - Issuance of Amendment 12/09/2013 document contains no new Regulatory Commitments.

239 Regarding Technical Specification 3.4.12 Licensee Supplements:

ADAMS Change for the Low Temperature RNP-RA/13-0067 03/31/2014, RNP-RA/12-0085, ML14079A523 The NRC issuance of the amendment has no discussion of ML14318A929 Overpressure Protection (LTOP) System ADAMS H.B. Robinson, Unit 2, Response to NRC regulatory commitments.

TAC (TAC No. MF2718). ML13357A189 Request for Additional Information Related to MF3267 Technical Specification Change Regarding Therefore, amendment 239 does not contain any misapplied Corrections to Table 3.3.1-1 Note 1. commitments.

Date The licensee's 6/20/2014 submittal states that there are no 05/26/15 Date regulatory commitments made in this submittal.

H. B. Robinson Steam Electric Plant, H. B. Robinson, Unit 2, Request for Technical Amendment 06/20/2014 Unit 2 - Issuance of Amendment Specifications (TS) Change Regarding 240 Licensee The NRC issuance of the amendment has no discussion of Regarding Technical Specification 5.5.9 Correction to TS 5.5.9.b.2, Steam Generator ADAMS RNP-RA/14-0053 regulatory commitments related to Robinson.

Steam Generator Program (TAC No. (SG) Program Accident-Induced Leakage ML15062A343 ADAMS MF4372). Performance Criterion.

TAC ML141888015 Therefore, amendment 240 does not contain any misapplied MF4372 commitments.

5

NRG Staff Licensee Document Document NRG Staff Document Title Licensee Staff Document Title Completion Notes Information Information H. B. Robinson, Unit 2, License Amendment The 6/7/2013 licensee submittal states that this letter Request To Modify Technical Specification contains no new Regulatory Commitments.

3.1.7 To Delete The Monthly Rod Position Date Indication Surveillance Requirements.

05/27/15 Date In the 7/24/2014 submittal, the licensee states that this letter H. B. Robinson Steam Electric Plant, Amendment 06/07/2013 contains no new Regulatory Commitments and no revision to Unit 2 - Issuance of an Amendment on Supplements:

241 Licensee existing Regulatory Commitments.

Rod Position Indication Technical 07 /24/2014, RNP-RA/12-0077, ML14219A010 ADAMS RNP-RA/13-0002 Specification Surveillance Requirements H. B. Robinson, Unit 2, Response to NRG ML15068A386 ADAMS The NRG issuance of the amendment has no discussion of (TAC No. MF1966). Request for Additional Information Regarding TAC ML13182A019 regulatory commitments.

License Amendment Request to Modify MF1966 Technical Specification 3.1.7 to Delete the Therefore, amendment 238 does not contain any misapplied Monthly Rod Position Indication Surveillance commitments.

Reauirements.

The 3/14/2012 licensee submittal makes no statements H. B. Robinson, Unit 2, lnservice Inspection regarding regulatory commitments.

Program for the Fifth Ten-Year Interval.

The 6/19/2012 licensee submittal states that this document Date Supplements: contains no new Regulatory Commitments.

10/01/2012 Date 06/19/2012, RNP-RA/12-0067, ML12187A249 Relief Reguest H. B. Robinson Steam Electric Plant, 03/14/2012 H. B. Robinson Steam Electric Plant, Unit 2 - The 7/26/2012 licensee submittal states that this document RR-2, 5th 10-year Unit 2 -Relief Request No. 2 for the fifth Licensee Response to the NRG Request for Additional contains no new Regulatory Commitments.

ADAMS 10-Year Interval lnservice Inspection RNP-RA/12-0023 Information Regarding lnservice Inspection ML12262A362 Program Plan (TAC No. ME8253). ADAMS Program Plan for the Fifth Ten-Year Interval. The NRG authorization of the alternative has no discussion of TAC ML12082A009 regulatory commitments. Note that this is this RR-2 is for the ME8253 07/26/2012, RNP-RA/12-0078, ML12220A501 lnservice Inspection Program. The next RR-2 is for the In-H.B. Robinson, Unit 2, Supplemental service Testing Program.

Information Regarding lnservice Inspection Program Plan for the Fifth Ten-Year Interval. Therefore, relief request 2 for the fifth 10-year cycle does not contain any misapplied commitments.

6

NRC Staff Licensee Document Document NRC Staff Document Title Licensee Staff Document Title Completion Notes Information Information H. B. Robinson Steam Electric Plant, Unit 2, Relief Request (RR)-7 from Immediate ASME The 10/5/2012 licensee submittal identifies 4 regulatory Code Repair of Refueling Water Storage Tank commitments.

Drain Value (Sl-837) for Fifth Ten-year lnservice Inspection Program Plan.

The 10/25/2012 licensee submittal states that this letter contains no new Regulatory Commitments.

Supplements:

10/25/2012, RNP-RA/12-0113, ML12312A272 The 11/11/2012 licensee submittal states that this letter Date H. B. Robinson Steam Electric Plant, Unit 2, contains no new Regulatory Commitments.

12/12/2012 Date Response to Request for Additional Information Relief Reguest H. B. Robinson Steam Electric Plant, 10/05/2012 Related to Relief Request (RR)-07 From The NRC authorization of the alternative provides a list of 6 RR-07, 5th 10-year Unit 2 -Relief Request No. 2 for the fifth Licensee Immediate ASME Code Repair of Refueling planned actions and regulatory commitments (from pages 5-6 ADAMS 10-Year Interval lnservice Inspection RNP-RA/12-0101 Water Storage Tank Drain Value (Sl-837) for of the enclosure to the licensee's 10/5/2012 submittal) but no ML12325A612 Program Plan (TAC No. ME8253). ADAMS Fifth Ten-Year lnservice Inspection Program other discussion. The list consists of the 4 regulatory TAC ML12292A386 Plan commitments from page two of the submittal interspersed ME9747 with 2 additional planned actions. Note that the authorization 11/11/2012, RNP-RA/12-0119, ML12340A441 is signed and dated but has not been made an agency H. B. Robinson, Unit 2, Supplemental record. LPL2-2 was notified on 10/9/2015 and the document Response to Request for Additional Information is in the process of being declared.

Related to Relief Request (RR)-07 from Immediate ASME Code Repair of Refueling Therefore, RR-07 for the fifth 10-year cycle does not contain Water Storage Tank Drain Valve (Sl-837) For any misapplied commitments.

Fifth Ten-Year lnservice Inspection Program Plan 7

NRC Staff Licensee Document Document NRC Staff Document Title Licensee Staff Document Title Completion Notes Information Information H. B. Robinson Steam Electric Plant Unit 2 -

lnservice Testing Program Plan for the Fifth-The 3/16/2012 licensee submittal has no discussion of Ten Year Interval.

regulatory commitments.

Supplements:

The 5/10/2012 licensee submittal states that this document 05/10/2012, RNP-RA/12-0056, ML12138A041 contains no new Regulatory Commitments.

H.B. Robinson, Unit 2 - Response to NRC Date Request for Additional Information for the Fifth 12/11/2012 The 6/4/2012 licensee submittal states that this document Date Ten-Year Interval lnservice Testing Program Relief Reguest contains no new Regulatory Commitments.

H. B. Robinson Steam Electric Plant, 03/16/2012 Plan.

IST RR-02, 5th 10-Unit 2 - Relief Request-2 for the Fifth 10- Licensee year The 9/20/2012 licensee submittal states that this letter Year Interval lnservice Testing Program RNP-RA/12-0017 06/04/2012, RNP-RA/12-0064, ML12165A261 ADAMS contains no new Regulatory Commitments.

Plan (TAC No. ME8259). ADAMS H. B. Robinson - Response to NRC Request ML12314A288 ML12086A067 for Additional Information Related to Relief TAC The NRC authorization of the alternative has no discussion of Requests (RR)-2 for the Fifth Ten-Year Interval ME8259 regulatory commitments. Note that this is this RR-2 is for the lnservice Testing Program Plan.

In-service Testing Program. The previous RR-2 is for the lnservice Inspection Program.

09/20/2012, RNP-RA/12-0093, ML12278A124 H. B. Robinson, Unit 2, Response to NRC Therefore, RR-2 for the fifth 10-year cycle does not contain Request for Additional Information Related to any misapplied commitments.

Relief Request-2 for the Fifth 10-Year Interval lnservice Testina Prooram Plan.

Date The 3/13/2013 licensee submittal states that this letter 07/16/2013 Date contains no new regulatory commitments.

H. B. Robinson Steam Electric Plant, Relief Reguest 03/13/2013 Unit 2, Relief Request-08 From ASME H. B. Robinson Steam Electric Plant, Unit 2, RR-8, 5th 10-year Licensee The NRC grant of relief has no discussion of regulatory Code Root Mean Square Error Value for Relief Request (RR)-8 from Fifth Ten-Year ADAMS RNP-RA/13-0018 commitments.

the Fifth 10-Year lnservice Inspection lnservice Inspection Program Plan.

ML13191A930 ADAMS Program Plan (TAC No. MF1015).

TAC ML13080A258 Therefore, RR-8 for the fifth 10-year cycle does not contain MF1015 anv misapplied commitments.

H. B. Robinson, Unit 2 - Relief Request (RR)-

The 8/27/2014 licensee submittal states that this letter 11 for Relief from VolumetridSurface contains no new regulatory commitments.

Date Examination Frequency Requirements of 02/17/2015 Date ASME Code Case N-729-1.

H. B. Robinson Steam Electric Plant, The 11/10/2014 licensee submittal states that there are no Relief Reguest 08/27/2014 Unit 2 - Relief Request (RR)-11 for Relief new regulatory commitments made in this letter.

RR-11, 5th 10-year Licensee Supplements:

from VolumetridSurface Examination ADAMS RNP-RA/14-0092 11/10/2014, RNP-RA/14-0124, ML14325A693 Frequency Requirements of ASME Code The NRC authorization of the alternative has no discussion of ML15021A354 ADAMS H. B. Robinson, Unit 2 - Response to Request Case N-729-1 (TAC No. MF4801). regulatory commitments.

TAC ML14251A014 for Additional Information Associated with MF4801 Relief Request (RR)-11 for Relief from Therefore, RR-11 for the fifth 10-year cycle does not contain VolumetridSurface Examination Frequency any misapplied commitments.

Reauirements to ASME Code Case N-729-1.

8

ML15288A472 OFFICE NRR/DORL/LPLll-2/PM NRR/DORL/LPLll-2/PM NRR/DORL/LPLll-2/LA NAME DGalvin MBarillas BClayton DATE 11/09/2015 11/10/2015 11/06/2015 OFFICE NRR/DORL/LPLI 1-2/BC NRR/DORL/LPLI 1-2/PM NAME BBeaslev MBarillas DATE 12/15/2015 12/16/2015