ML15334A125
| ML15334A125 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 12/23/2015 |
| From: | Andrea George, Robert Schaaf Plant Licensing Branch II, Plant Licensing Branch IV |
| To: | James Shea, Skaggs M Tennessee Valley Authority |
| George A | |
| References | |
| CAC MF6745, CAC MF6746 | |
| Download: ML15334A125 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 23, 2015 Mr. Michael D. Skaggs Mr. Joseph W. Shea Senior Vice President Vice President, Nuclear Licensing Watts Bar Operations and Construction Tennessee Valley Authority Tennessee Valley Authority 1101 Market Street, LP 3-R-C P. 0. Box 2000, EQB IB-WBN (NP91) Chattanooga, TN 37 402-2801 Spring City, TN 37381 SUBJECT WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 -AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (CAC NOS. MF67 45 AND MF67 46)
Dear Mr. Skaggs and Mr. Shea:
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 that regulatory commitments are being effectively implemented.
An audit of Watts Bar Nuclear Plant's (WBN's) commitment management program was performed at the WBN site during the period November 17 - 20, 2015. The NRC staff concludes, based on the audit, that (1) WBN has implemented NRC commitments on a timely basis, and (2) has implemented a generally effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely, Robert G. Schaaf, Senior Project Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-390 and 50-391
Enclosure:
Audit Report cc: Distribution via Listserv
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-390 AND 50-391
1.0 INTRODUCTION AND BACKGROUND
The U.S. Nuclear Regulatory Commission (NRG) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRG Staff, dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRG 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 NRG. NEl-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRG.
The NRG 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 that regulatory commitments are being effectively implemented. An audit of the Watts Bar Nuclear Plant (WBN) commitment management program was performed at the WBN site during the period November 17 - 20, 2015. The audit reviewed commitments made since the previous audit on November 9, 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 NRG 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 NRG commitments that have been completed, (2) verification of the licensee's program for managing changes to NRG commitments and (3) verification that all regulatory commitments reviewed were correctly applied in NRG staff licensing action reviews.
2.1 Verification of Licensee's Implementation of NRG Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRG as part of past licensing actions/activities. For commitments not yet implemented, the NRG 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 Audi~ 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 NRG 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 NRG staff searched Agencywide Document Access and Management System 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 NRG 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. 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 NRG staff sampled 37 commitments between the two units and all sampled commitments were identified in the licensee's commitment tracking system.
2.2 Verification of the Licensee's Program for Managing NRG 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 NRG. The NRG staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRG has found to be an acceptable guide for licensees to follow for managing and changing commitments. Since the previous audit conducted in November 2012, the procedure used at WBN, Unit 1, Nuclear Power Group Standard Programs and Processes (NPG-SPP) 3.3 "NRG Commitment Management," underwent a major revision in August 2015.
As part of this audit, the NRG staff reviewed the differences between the old and new revisions
to the procedure. The audit also reviewed the regulatory commitment program procedure for WBN, Unit 2, New Construction Project Procedure 19 (NC PP-19), "Closure of Commitments/Open Items Required for Licensing." The audit also 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. In addition, the NRC staff reviewed the self-assessments (Numbers CRP-LIC-S-13-002, CRP-LIC-S-14-002, and CRP-LIC-SSA 005) of the implementation effectiveness of NPG-SPP 3.3 by Tennessee Valley Authority (TVA)
Nuclear Power Group (Corporate) Licensing in October 2013, December 2013, and October 2015.
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 one example where TVA had closed a regulatory commitment without proper closure justification and without completing the commitment as stated in correspondence to the NRC (commitment Number NC0081008001). When informed, TVA staff entered a condition report (CR) 1105787 to determine whether the commitment should be reopened. The NRC staff has no further questions regarding this item. Additionally, the NRC staff observed minor administrative errors in the commitment tracking database (CTD), such as missing data fields required to be filled by NPG-SPP 3.3, minor discrepancies in closure documentation (e.g.,
an erroneous closure date), and some instances where the commitment wording in the CTD did not match the docketed regulatory commitment.
The NRC staff found that the new revision of NPG-SPP 3.3 (Revision 6) is consistent with the guidance contained in NEI 99-04. Regarding NC PP-19, the NRC staff found that the procedure for processing regulatory commitments at WBN, Unit 2, is not consistent with the guidance in NEI 99-04, in that it lacked a codified commitment change evaluation process. When informed, TVA staff stated that all commitment changes for WBN, Unit 2, were communicated in writing to the NRC; however, this process was not included in the NC PP-19 procedure. The NRC staff notes that since the August 2015 revision of NPG-SPP 3.3, the WBN, Unit 2, licensing staff has been following NPG-SPP 3.3 for Unit 2 commitments, including the commitment change evaluation process (except for commitment closure, which is still under NC PP-19). The licensee entered a CR for this issue (CR 1105976). The NRC staff notified the WBN, Unit 2, resident inspectors of this discrepancy, and will follow up with the licensee on corrective actions to ensure any open Unit 2 commitments were changed appropriately while under the NC PP-19 procedure. The NRC staff concludes that the approach of communicating all WBN, Unit 2, commitment revisions in writing to the NRC is conservative in relation to the NEI 99-04 guidance and is, therefore, acceptable.
2.3 Review to Identify Misapplied Commitments The commitments reviewed for this audit were also evaluated to determine if they had been misapplied. A commitment is considered to be misapplied if the action comprising the commitment was relied on by the NRC staff in making a regulatory decision such as a finding of public health and safety in an NRC safety evaluation associated with a licensing action.
Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if
the commitment involves actions that were safety significant (i.e., commitments used to ensure safety).
Each of the commitments selected for the audit sample were reviewed to determine if any had been misapplied. None of the commitments selected for the audit sample were determined 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, exemption and relief request safety evaluations that have been issued for WBN since the last audit were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above. The evaluation concluded that none of these documents contained any misapplied commitments.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) WBN has implemented NRC commitments on a timely basis, and (2) has implemented a generally effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Beverly Duckett - Watts Bar Licensing Jim O'Dell - Watts Bar Licensing Timothy Page - TVA Corporate Licensing Thomas Elton - Watts Bar Licensing Russell Stroud - Watts Bar Licensing Principal Contributors: Jennifer Hauser Andrea George Date: December 23, 2015
Attachment:
Summary of Audit Results
AUDIT
SUMMARY
IMPLEMENTATION OF COMMITMENTS:
The following commitment samples were reviewed:
Description Commitment ADAMS Comments Tracking No. Reference Unit 1 By March 31, 2013, TVA will install a permanent plant 113637263 ML12171A053 This commitment was closed after modification to provide flood protection with respect to flood barriers were installed by the Design Basis Flood level for the WBN, Unit 1 commitment due date of 3/31 /13.
Thermal Barrier Booster pumps and motors.
Revise Radiological Emergency Plan (REP) PAR 116118710 ML15205A124 This commitment was closed upon Flowcharts and alternate facility descriptions NP-REP ML15205A110 submittal of updated REP to NRC on will be revised to replace both pages of Figure 10-1 to 9/12/14.
update the PAR Flowcharts for NUREG 0654, Supplement 3 guidance. In addition, the NP-REP will be revised to include descriptions of the alternate facilities.
Update Updated Final Safety Analysis Report 114978890 ML13228A264 This commitment was closed after (UFSAR) for Generic Letter (GL) 1988-17. Each WBN the Unit 2 FSAR was updated to unit will update its respective Safety Analysis Report reflect the Unit 1 wording regarding (i.e., UFSAR for Unit 1 and Final Safety Analysis two different monitoring systems Report (FSAR) for Unit 2) to reflect this different (Unit 1 FSAR was already worded means of providing two different monitoring systems. correctly).
TVA will revise the UFSAR to include the following, as 115086708 ML13248A250 This commitment was closed due to part of the adoption of TSTF-500, Rev 2. As identified ML14178B301 LAA being withdrawn on 6/20/14.
in License Amendment Request (LAR) The commitment change evaluation WBN-TS-12-07. process was aoolied appropriately.
Within 6 months of NRC approval, TVA will evaluate NC0081008001 ML082890540 This commitment was closed with adopting the revised ISTS-523, Surveillance insufficient justification and without Requirement (SR) 3.5.2.3 at WBN within 6 months of completing the commitment as stated NRC approval of the traveler. in correspondence to NRC (licensee Condition Report 1105787). The commitment change evaluation Attachment
process was applied appropriately for chanqes to this commitment.
Monitoring of battery parameters (i.e., specific gravity, 115086759 ML13248A250 This commitment was closed due to electrolyte level, cell temperature, float voltage, ML14178B301 LAR being withdrawn on 6/20/14.
connection resistance, and physical condition) will be The commitment change evaluation relocated to the licensee-controlled program as process was applied appropriately.
required and described in Technical Specifications (TS) Section 5.7.2.21, "Programs and Manuals,": and titled the "Battery Monitoring and Maintenance Proa ram."
TVA verifies that the equipment that will be used to 115086730 ML13248A250 This commitment was closed due to monitor float current under SR 3.8.6.1 and SR 3.8.6.2 ML14178B301 LAR being withdrawn on 6/20/14.
will have the necessary accuracy and capability to The commitment change evaluation measure electrical currents in the expected range. process was applied appropriately.
Additionally, TVA verifies that the minimum required procedural time to measure battery float current will be 30 seconds or as recommended by the float current measurement instrument manufacturer. This minimum float current measurement time is required to provide a more accurate battery float current readinq.
TVA verifies that the modified performance discharge 115086798 ML13248A250 This commitment was closed due to test for each diesel generator (DG) battery completely ML14178B301 LAR being withdrawn on 6/20/14.
encompasses the load profile of the battery service The commitment change evaluation test and that it adequately confirms the intent of the process was applied appropriately.
service test to verify the DG battery capacity to supply the desian basis load profile.
The cell resistance limits in existing SR 3.8.4.5 will be 115086683 ML13248A250 This commitment was closed due to relocated to the Battery Monitoring and Maintenance ML14178B301 LAR being withdrawn on 6/20/14.
Program. The commitment change evaluation process was applied appropriately.
TVA verifies that plant procedures will require 115086780 ML13248A250 This commitment was closed due to verification of the selection of the pilot cell or cells ML14178B301 LAR being withdrawn on 6/20/14.
when performing SR 3.8.6.5. Note: The current The commitment change evaluation methodology selects a "representative" cell annually process was applied appropriately.
that has averaqe voltaae and specific qravitv. The new
methodology selects the lowest voltage cell in each battery.
TVA verifies that battery room temperature is routinely 115086745 ML13248A250 This commitment was closed due to monitored such that a room temperature excursion ML141788301 LAR being withdrawn on 6/20/14.
could reasonably expect to be detected and corrected The commitment change evaluation prior to the average battery electrolyte temperature process was applied appropriately.
dropping below the minimum electrolyte temperature.
Battery Room Temperature will be monitored at least every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> durinq operator tours.
TVA will install flood mode hardened 3.0 megawatt 114618505 ML13108A107 This commitment was closed upon electric (MWe) Diesels (one per operating unit) ML14275A239 installation of two 225 kilo-volt-designed to provide extended coping in accordance ampere (kVA) DGs per NRC Order with NEI 12-06 guidance as described for Mileston~ 2 EA-12-049 requirements. The in the Table in Enclosure 1 of the commitment letter by commitment change evaluation August 2014. process was applied appropriately to change the DG specifications.
TVA will install a hardened enhanced flood mode 114620087 ML13108A107 This is an open commitment. The system for decay heat removal as described for ML14275A239 commitment change evaluation Milestone 3 in the Table in Enclosure 1 of the process was applied appropriately to commitment letter by December 2016. change the responsible supervisor and the completion date.
TVA will include a procedural action to place an 117034467 ML15215A649 This commitment is open. The text Auxiliary Feedwater pump in pull-to-lock prior to in the CTD does not match the starting a second emergency raw cooling water pump regulatory commitment made in the on a shutdown board when the shutdown board is correspondence to the NRC, which powered by the diesel generators. was corrected by the licensee.
TVA will construct a flood mode hardened structure 114617987 ML13108A107 This is an open commitment. The that will meet or exceed NEI 12-06 as described for ML14275A239 commitment change evaluation Milestone 1 in the Table in Enclosure 1 of the process was applied appropriately to commitment letter by November 2015. change the responsible supervisor, the completion date, and the location of enhanced flood mode equipment.
Description Commitment ADAMS Comments Tracking No. Reference Unit 2 WBN Unit 2 will include backup generator 113654301 ML110890562 This commitment was closed after procedure(s) to include supplying one train of operator training was completed containment hydrogen igniters per unit and train (3-0T-B5b) and revised procedures personnel to the procedure. were issued.
The Regulatory Framework status for Supplemental 114351907 ML13030A031 This commitment was closed due to Safety Evaluation Report (SSER) Appendix HH shown ML13088A066 an NRG inspection report closing out in Reference 1 will be revised to reflect the anchor bolt Open Item 50, and the justification verification methodology described in this letter in the that a change to the regulatory next update. framework was not required due to the Open Item not being tied to any portion of the SSER for the operating license for Unit 2.
The information provided in Enclosure 4 will be 114957518 ML13225A021 This commitment was closed after incorporated into the WBN Unit 2 FSAR by ML13255A164 submitting FSAR Amendment 11 O to Amendment 11 O. the NRG. The NRG staff verified that the FSAR changes pertinent to this commitment remained in the most recent FSAR update (Amendment 114).
The TVA WBN Unit 2, NPG System Description 115514895 ML14038A079 This commitment was closed after Document, NPG-SDD-WBN2-82-4002, "Standby the appropriate NPG system Diesel Generator System" shall be revised to describe description document was updated.
the DG frequency and voltage governor setting methodology.
TVA will add the License Condition to WBN Unit 2 116123812 ML14247A231 This commitment was closed due to FSAR Section "8.2.2 Analysis" as part of WBN Unit 2 ML15076A388 submittal of the specified updates to FSAR Amendment 113. WBN Unit 2 FSAR the NRG in Amendment 113 of the Amendment 113 will be issued on or before FSAR.
October 30, 2014.
The Watts Bar Nuclear Plant Unit 2 TSs will be 116439570 ML14352A248 This commitment was closed based updated by January 30, 2015, to reflect the higher ice ML15187A461 on submittal of the required updates mass described in Enclosure 2 of this letter. to the TSs and TS bases to the NRC.
The long term containment pressure analysis will be 117060676 ML15225A382 This commitment was closed due to included in WBN Unit 2 FSAR Amendment 114. ML15279A332 the required information being included in the Unit 2 FSAR Amendment 114, which was submitted to the NRC by letter dated 9/11/15.
Revised ice weights for the ice bed and ice baskets 117060649 ML15225A382 This commitment was closed due to will be incorporated in SR 3.6.11.2 and SR 3.6.11.3, ML15267A183 the updated TSs being submitted to respectively, in WBN Unit 2 TS Revision 0. the NRC by letter dated 9/23/15.
The caution statement, "CAUTION: Both Units shall 117199011 ML15265A100 This commitment is open.
not be placed in Hot Shutdown simultaneously," will be added to the Watts Bar Nuclear Plant (WBN) System Description Document WBN-SSD-N3-70-4002, "Component Cooling System," prior to initial Mode 4 entry of WBN Unit 2.
The caution statement, "CAUTION: Both Units shall 117198968 ML15265A100 This commitment is open.
not be placed in Hot Shutdown simultaneously," will be added to the WBN General Operating Instructions 1-G0-6 and 2-G0-6, "Unit Shutdown from Hot Standby to Cold Shutdown," prior to initial Mode 4 entry of WBN Unit 2.
Prior to fuel load, it will be confirmed that the Unit 2 111029124 ML100491535 This commitment was closed due to Probabilistic Risk Assessment model matches the ML14177A724 the submission of the required PRA as-built, as-operated plant. calculations to the NRC by letter dated 6/25/14.
WBN is interested in the new seal package technology 111891340 ML11145A088 This commitment was closed due to being demonstrated by Westinghouse at the Farley ML15103A209 the analysis being submitted to the Nuclear Plant (Severe Accident Management NRC by letter dated 4/10/15.
Alternative (SAMA) 58). However, prudency dictates that additional operation experience is needed prior to our implementation of SAMA 58. Therefore, WBN commits to follow the proQress and experience with
this seal package design and if proven reliable during operation, it would be installed at the earliest refueling outage following startup during normal seal package replacements.
In addition to the previous commitment, TVA WBN 111377435 ML100950044 This commitment was closed due to Unit 2 will ensure that the guidance added to the Unit procedure updates with the steps to 1 procedure as a result of the review of NRC GL 98-02 positively control HCV-74-34 during is incorporated into the Unit 2 procedures. Specifically, startup and shutdown (procedures when decreasing power, valve HCV-74-34, Refueling 2-G0-6, "Unit Shutdown from Hot Water Return (normally locked closed valve) has a Standby to Cold Shutdown," and hold order placed with specific release criteria before 2-G0-1, "Unit Startup from Cold entry into Mode 4 and to remove the hold order before Shutdown to Hot Standby").
entrv into Mode 3 when returning to power.
Procedural controls will be put in place at WBN Unit 2 112044502 ML110680248 This commitment was closed due to to ensure that potential quantities of post-accident ML110430002 the appropriate procedures being debris are maintained within the bounds of the ML14163A658 modified.
analyses and design bases that support emergency core cooling system (ECCS) and containment spray system recirculation functions.
Operating procedures are being revised to improve 112054449 ML112232205 This commitment was closed after instructions for filling and venting portions of the ECCS ML110750022 updating the ECCS operating discharge pipe (90 days prior to fuel load). instruction appropriately. This item was also covered in an NRC inspection report.
Periodic venting procedures used to meet SR 3.5.2.3 112054461 ML112232205 This commitment was closed after are being revised to require that, for an extended gas ML110750022 updating the ECCS operating release, a report is entered into the Corrective Action instruction appropriately. This item Program (90 days prior to fuel load). was also covered in an NRC inspection report.
As resolution of this request for additional information, 112345687 ML102360283 This commitment was closed after TVA commits to completing prior to Unit 2 fuel load the ML13044A113 completing modifications required modifications and document revisions required to and closing out MSOs in Revision 2 resolve the common multiple spurious operations of the MSO Evaluation Report (MSOs) identified in Appendix C submitted in TVA R1976-20-01 dated January 2013.
letter to NRC dated August 20, 201 O.
"Charging Pump Runout" shall be confirmed to be 111905994 ML102360283 This commitment was closed due to within the bounds of centrifugal charging pump ML13044A113 updating the MSO Evaluation operation during the large break loss-of-coolant described above and the Appendix R accident analysis prior to Unit 2 fuel load. fire hazard analysis and safe shutdown analysis.
Incorporate a temperature limitation during heatup and NC0920071003 ML080320443 This commitment remains open, but cooldown operations into Unit 2 procedures. ML13023A315 the licensee has documented partial closure due to issuance of two of three required procedures to comply with the commitment.
Have safety parameter display system operational NC0830138002 ML080320443 This commitment was closed after prior to start-up after the first refueling outage. completion of testing per integrated computer system operability test plan.
Implement Maintenance Rule for Unit 2 systems by NC0080008068 ML080320443 This commitment was closed after June 20, 2014. ML103210644 implementing two unit procedures:
ML11292A199 NPG-SPP-03.4, "Maintenance Rule ML12284A514 Performance Indicator Monitoring, Trending and Reporting - 10 CFR
[Code of Federal Regulations]
50.65," Revision 2, and Technical Instruction O-Tl-119, "Maintenance Rule Performance Indicator Monitoring, Trending and Reporting -
10 CFR 50.65," Revision 0. This commitment was revised four times with each change communicated to the NRG in writinq.
TVA will install flood barrier modifications to prevent NC0080008054 ML080320443 This commitment was closed after water damage to WBN Unit 2 Component Cooling ML14085A009 installing the required flood barriers System Thermal Barrier Booster Pumps in the event (verified by NRG inspection), and of a Probable Maximum Flood before WBN Unit 2 closeout of the open item in NRG receives an operatinq license. SSER 27, Section 9.2.2.
ML15334A125 OFFICE DORL/LPLI 11-2/PM DORL/LPLll-2/PM DORL/LPLI 1-2/LA DORL/LPLI 1-2/BC DORL/LPLI 1-2/PM NAME JHauser RSchaaf BClayton BBeasley RSchaaf DATE 12/18/2015 12/22/2015 12/17/2015 12/23/2015 12/23/2015