ML15338A193

Audit of Exelon Generation Company, Llc'S Management of Regulatory Commitments

ML15338A193
Person / Time
Site:	Three Mile Island
Issue date:	04/26/2016
From:	Robert Gladney Plant Licensing Branch 1
To:	Bryan Hanson Exelon Nuclear
Gladney R, NRR/DORL/LPLI-2
References
CAC MF6608
Download: ML15338A193 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 26, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - AUDIT OF EXELON GENERATION COMPANY, LLC'S MANAGEMENT OF REGULATORY COMMITMENTS (CAC NO. MF6608)

Dear Mr. Hanson:

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. The previous audit of the licensee's commitment management program for Three Mile Island Nuclear Station, Unit 1 (TMl-1) was documented in an NRC letter dated December 28, 2012 (Agencywide Documents Access and Management System Accession No. ML12348A353).

An audit of the commitment management program for TMl-1 was performed during the last quarter of 2015, with the onsite portion taking place October 13 - 16, 2015. As a result of the

B. Hanson audit, the NRC staff concludes that TMl-1 has implemented NRC commitments on a timely basis and TMl-1 has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.

Sincerely,

• -ilkfI Robert L. Gladney, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

Audit Report cc w/enclosure: Distribution via Listserv

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF REGULA TORY COMMITMENTS MADE BY EXELON GENERATION COMPANY, LLC TO THE NUCLEAR REGULATORY COMMISSION FOR THREE MILE ISLAND NUCLEAR STATION, UNIT 1 DOCKET NO. 50-289

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 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes" (ADAMS Accession No. ML003680088), 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. NEl-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

The 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 that regulatory commitments are being effectively implemented. 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.).

An audit of the commitment management program for Three Mile Island Nuclear Station, Unit 1 (TMl-1) was performed during the last quarter of 2015, with the onsite portion taking place October 13 - 16, 2015. The previous audit of the licensee's commitment management program for TMl-1 was documented in an NRC letter dated December 28, 2012 (ADAMS Accession No. ML12348A353).

2.0 AUDIT PROCEDURE AND RESULTS The audit was performed in accordance with the guidance in NRR Office Instruction LIC-105, Revision 5, "Managing Regulatory Commitments Made by Licensees to the NRC," dated September 16, 2013 (ADAMS Accession No. ML13193A358). The NRC staff reviewed commitments made during the period since the previous audit. 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 Enclosure

commitments; and (3) verification that all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews.

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

Prior to the audit, the licensee provided the NRC staff with a list of regulatory commitments from its PassPort Action Tracking Program, which is the licensee's system used for commitment management at TMI, as well as the applicable regulatory commitment management procedures.

The licensee's list of regulatory commitments included open commitments, commitments initiated since December 2012 (and prior), and commitments closed within the audit window.

The license also provided the previous biennial report to the NRC containing commitments that were changed in 2012 and 2013. 1 During the onsite portion of the audit, the licensee provided additional documentation for the commitments requested for the audit, as well as several commitment change evaluation forms (CCEFs) and other documentation for commitments changed from 2013 to 2015. For the sampled commitments, the licensee provided PassPort Tracking Numbers (Exelon Tracking Nos.), brief commitment descriptions, licensee letter numbers, commitment due dates and completion dates, and other associated documentation.

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.). Before the audit, the NRC staff searched ADAMS for the licensee's submittals since the last audit and selected a representative sample for verification. The commitments included in the review are described in Table 1 of this Audit Report.

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.

1 "Three Mile Island Nuclear Station, Unit 1 - Biennial 10 CFR 50.59 and Commitment Revision Reports for 2012 and 2013" (ADAMS Accession No. ML14106A020), dated April 16, 2014, for 2012 and 2013 commitments.

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

2.1.2 Audit Results Table 1 provides the results of the audit for the verification of the licensee's implementation of commitments. For the sampled commitments, the NRC staff determined that the licensee had appropriately implemented the closed commitments and scheduled the open commitments for future implementation. The staff also determined that the commitment tracking database allows for the adequate traceability of implemented commitments. There were no significant issues identified for this part of the audit. Section 2.4 of this report provides additional observations.

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 TMl-1 is primarily contained in licensee procedures LS-AA-110, Revision 11, "Commitment Management," and LS-AA-110-1001, Revision 7, "Commitment Tracking Program T&RM 2 [Training and Reference Material]: For Use with PassPort." This part of the audit also included a review of a sample of commitment changes, as described in Table 2, which 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 NRC staff reviewed the licensee's procedures LS-AA-110, Revision 11 and LS-AA-110-1001, Revision 7, against NEI 99-04 to ensure that guidance in this procedure is consistent with the intent of NEI 99-04, and that the licensee is appropriately implementing regulatory commitment changes, as well as tracking changes to the commitments. Section 6.1 of LS-AA-110 lists NEI 99-04 as a reference. The NRC staff found that the procedures generally follow the guidance of NEI 99-04 and provide detailed instructions for making regulatory commitments, tracking regulatory commitments, annotating documents to provide traceability of commitments, and for making changes to commitments. The NRC staff concludes that the procedures used by the licensee to manage commitments provide the necessary attributes for an effective commitment management program.

During the audit, the NRC staff observed that the licensee had provided, "Three Mile Island Nuclear Station, Unit 1 - Biennial 10 CFR [Title 10 of the Code of Federal Regulations] 50.59 and Commitment Revision Reports for 2012 and 2013," dated April 16, 2014, for 2012 and 2013 commitments, but had not provided a report of 2014 and 2015 commitment revisions. NEI 99-04 does not limit the licensee to only annual reporting to the NRC, but instead requires "notification to the NRC made in a report submitted annually or along with the FSAR updates as 2 The licensee provides this acronym as part of the procedure title.

required by 10 CFR 50.71 (e)." However, licensee procedure LS-AA-110, step 4.7.3, does require that a written report of commitment changes be submitted to the NRC every calendar year. The NRC resident inspectors provided the NRC auditor with licensee Assignment Report (AR) 02568457, which the licensee had previously written to document the issue, take the immediate action to discuss this with site and corporate licensee personnel, and to schedule actions to submit reports to the NRC in 2016 and 2017. As a result, the NRC staff expanded this portion of the commitment audit sample to include 2014 and 2015 commitments. In addition, the NRC auditor and resident inspectors discussed this issue with the licensee during the audit and at the exit meeting.

In addition, the NRC staff observed that while the licensee is required to complete LS-AA-110, , "Commitment Change Evaluation Form," per LS-AA-110, Section 4.6, there were instances in which a CCEF was not available. As detailed in Table 2 of this report, there were several commitments in which the licensee notified the NRC of the commitment changes and is tracking them in the licensee commitment tracking database, but did not have an available CCEF. The NRC staff discussed this requirement with the licensee.

Table 2 provides the detailed results of the audit of commitment changes for TMl-1. There were no significant issues identified in this part of the audit. However, some observations were made, as explained above and in Section 2.4 of this report.

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 safety-significant actions (i.e., commitments used to ensure safety).

The current version of LIC-105, Revision 5, states that the NRC staff should take the following actions to identify misapplied commitments:

( 1) Determine if the commitment reviewed involves actions that were safety significant (i.e., commitments used to ensure safety).

(2) Determine if the commitment reviewed involves actions that were necessary for approval of a proposed licensing action.

The scope of this portion of the audit includes reviewing each of the commitments selected for the audit sample (i.e., Tables 1 and 2) to determine if any had been misapplied (per the two criteria shown above). No misapplied commitments were identified for this portion of the audit.

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, all license amendment, relief request, and exemption safety evaluations that have been issued for a facility since the previous audit were identified. Table 3 lists each of these documents for TMl-1. The NRC staff identified all commitments discussed in these documents and evaluated each commitment to determine if it had been misapplied based on the two criteria discussed in Section 2.3.1 of this report.

The details and results for this portion of the audit are provided in Table 3 of this report. No misapplied commitments were identified for this portion of the audit.

2.4 Audit Observations During the audit, the NRC staff had the following observations. These observations were communicated to the licensee during the audit.

(1) The NRC staff observed that commitments for multiple Exelon Generation Company, LLC (Exelon) plants are maintained in the same commitment tracking database. However, the licensee is able to easily and effectively narrow its search criteria to TMl-1 commitments.

Tracking the commitments in this database also allows the licensee to maintain consistency with how it manages various commitments across its fleet.

(2) As indicated previously in this report, the licensee primarily uses two procedures for commitment management at TMl-1: LS-AA-110 and LS-AA-110-1001. While another procedure, LS-AA-110-1002, "Commitment Tracking Program for Use with PIMS," is also used at other plants within the Exelon fleet for commitment management, the licensee indicated that the Plant Information Management System is used at TMl-1 for corrective actions and not for commitment management. None of these commitment management procedures provide information regarding which are used at each specific site and under what conditions they should be utilized. The licensee should provide clarifying guidance in a procedure or other document so that this information is readily available.

(3) Licensee procedure LS-AA-110, step 4.7.3, requires the licensee to submit an annual commitment revision report to the NRC. During the audit, the NRC staff observed that the last summary report submitted was by letter dated April 16, 2014, which addressed 2012 and 2013 commitments. No summary report was submitted for 2014 commitments.

Prior to the onsite portion of the audit, the licensee identified that it had not submitted this annual report. The licensee wrote AR 02568457, "Commitment Changes Not Submitted to NRC Annually," on October 9, 2015, which is described below and in Section 2.2.1 of this report, and included actions to address this issue.

• Actions regarding AR 02568457:

o This AR noted that although LS-AA-110, step 4.7.3, requires an annual summary report to the NRC for commitment revisions, the practice has been to submit it with the 10 CFR 50.59 report biennially, per LS-AA-104, "Exelon 50.59 Review Process."

o The immediate action taken was that the site and corporate Regulatory Assurance groups discussed the procedural requirement for sending an annual report of commitment changes.

o Recommended actions included providing a report of 2014 and 2015 commitment changes to the NRC in April 2016, and creating an assignment to report 2016 commitment changes by March 31, 2017. In addition, the licensee's staff provided CCEFs 14-01through14-09, 15-01, and 15-02, and associated documentation, to the NRC staff during the onsite portion of the audit.

Accordingly, the NRC staff expanded its sample of commitments evaluated in the audit to include samples from this subset.

(4) Licensee procedure LS-AA-110, Section 4.6, requires that CCEFs (LS-AA-110, Attachment 1) be completed for all commitment changes. The NRC staff determined that there were commitment changes for which CCEFs were not provided. Included within this issue is a conflict in licensee procedures LS-AA-110 and LS-AA-110-1001, since LS-AA-110, step 4.6.4, item 6, states that, "If the proposed change is rejected, then the requester may discard the CCEF," whereas LS-AA-110-1001, step 5.1, states that, "Documentation associated with regulatory commitment changes shall be maintained for the life of the facility as a 'life of the plant' record." The licensee wrote AR 2596888 to address this issue by evaluating LS-AA-11 O and to make changes, as appropriate, so that it provides additional guidance and clarification for CCEF documentation and retention.

(5) The licensee is able to track commitments by classifying them as such in its database, but there are no separate classifications for commitment revisions and obligations. The NRC staff observed that while the licensee can perform a word search to find commitment revisions and obligations within its commitment tracking database, it would be more effective if these items could be more easily classified, identified, and tracked.

Another observation was described in TMI Integrated Inspection Report 5000289/2015003 (ADAMS Accession No. ML15306A380), dated November 2, 2015, which documented a finding of very low safety significance (Green). This finding did not involve an NRC violation but was concerning a commitment from original plant construction that was not implemented. The resident inspectors determined that the licensee failed to perform fire service system modifications for mitigating the potential impact of a pipe rupture in the auxiliary building as committed to the NRC in a letter dated November 10, 1972. As stated in the inspection report, this was determined to be a Green finding because, "the finding is not a design or qualification deficiency, does not represent a loss of system safety function or loss of a single train for greater than its allowed TS time, does not result in the loss of a high safety-significant maintenance rule train and does not involve the loss of function to mitigate internal flooding

events." The inspection report indicated that the licensee documented this in Incident Report (IR) 2544387, performed an immediate operability evaluation, and developed corrective actions.

(AR 2547232 was also written and incorporates additional actions.)

In addition, the licensee documented an error regarding Exelon Tracking No. 1122072-01 in IR 2449863, "Commitment Frequency Changed Out of Process." In this IR, the following was stated:

Generic Letter 89-13 Program basis document ER-TM-340-1001 contains commitment 32, perform AH-C-4B Control Building Chiller Annual Inspection (PM000269). Per the Generic Letter commitment, this inspection is to be done on a one year frequency. In May of 2013, the frequency was changed by a system engineer to 1.5 years via AR [evaluation] A2277159-69 and no commitment change was processed.

As described above, the preventive maintenance (PM) frequency associated with the referenced commitment had been temporarily changed out of process from 1 year to 1.5 years.

Based upon the licensee's documentation, the PM frequency was changed due to reliability issues with the opposite train chiller and because the initiator of the change did not realize that the PM frequency was associated with a regulatory commitment.

• Actions regarding IR 2449863:

o As an immediate action, the licensee discussed this with the system engineer for processing of the frequency correction in accordance with evaluation A1721611-10.

o Recommended action also included performing a review of all PM activities that implement GL 89-13 commitments to ensure that the PM activities have the correct frequencies and appropriate language.

3.0 CONCLUSION

The NRC staff concludes, based on the audit, that (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) the regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT R. Miller D. Atherholt M. Fitzwater F. Mascitelli Principal Contributor: R. Gladney Date: April 26, 2016 Attachments: Table 1, "Reviewed Licensee Commitments (TMl-1 )"

Table 2, "Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1 )"

Table 3, "Review of NRC License Amendments, Relief Requests, and Exemptions (TMl-1 )"

TABLE 1 Reviewed Licensee Commitments (TMl-1)

(See Note 1)

TMl-1 NRC NRC Source/ Summary of Regulatory Commitment Licensee Implementation Submittal CAC Issuance Status and Tracking No. (if Date No. aoolicable) 10/18/12 ME9818 RR-12-02, dated As stated by the licensee: Complete.

(ML12292A584) 6/10/2013 "[Provide] the results of the ultrasonic examination of the Full (ML13134A467) Structural Weld Overlay on the TMI, Unit 1 lower cold leg The Safety Evaluation (SE) states:

letdown nozzle dissimilar metal welds and Alloy 600 safe-end. "The licensee will provide the results The results will include: (1) A list of the indications detected, within 30 days after the completion of (2) The disposition of all the indications using the standards of the last UT examination of weld ASME Code Cases N-740-2 and N-770-1, (3) The type and, if overlays during the Fall 2013 TMl-1, possible, nature of the indications. Also included in the results T1 R20 refueling outage. The NRC will be a discussion of any repairs to the overlay material." staff reviewed this commitment and finds it acceptable. The NRC staff also concludes that tracking this commitment under the licensee's commitment tracking program is appropriate."

Exelon letter TM 1-13-168 (ML13338A431), dated 12/3/2013, discussed the closeout of the commitment and did not contain new commitments. The letter states:

"During the recent TMI, Unit 1 refueling outage, the identified welds were successfully overlaid. Ultrasonic examinations of these overlays did not identify any indications.

Additionally, there were no repairs to the overlay material. Accordingly, this commitment is complete."

(Exelon TrackinQ No. 1428966-01)

Letter dated ME9989 Safety Assessment This commitment involves TMl's Emergency Plan (EP). The Closed.

10/31112 of Communications, licensee's letter dated 10/31/12 states: "EGC will install EP (ML12306A199) dated 7/12/13 communications equipment as described in Attachment 10 The licensee's submittal had a due

s. 10/14/14 (ML13114A067) (Planned or Potential Improvement Identified column) at the date of fall 2015 for TMI in ML14287A659 [TMI], and complete appropriate training to response personnel Attachments 11 and 12. It is Exelon (non-public) and corporate ERO members pertaining to location, purpose Tracking No. 1362747-55-00, and the and use of the communications equipment." This commitment licensee closed this item on 11/24/15.

was revised by the licensee letter dated 10/14/14 so that instead (The commitment for the NEI 12-01 of ourchasina satellite communications trailers with cellular communications strateov is related Attachment 1

TABLE 1 Reviewed Licensee Commitments (TMl-1)

(See Note 1)

TMl-1 NRC NRC Source/ Summary of Regulatory Commitment Licensee Implementation Submittal CAC Issuance Status and Tracking No. (if Date No. aoolicable) phones as a method for maintaining offsite communications, and is Exelon Tracking No.

Exelon was to provide satellite dish communication systems 1362747-59.) The intent of the consisting of portable and fixed elements. original commitment appears to have been satisfactorily met.

Licensee letter MF0185 NRC Request for This commitment involves the Seismic Walkdown Deferred Complete.

dated 11/19/12 Information Inspections for TMI. Licensee letter RS-12-175/ TMl-12-161, (RS-12-175, Pursuant to Title 10 dated 11 /19/12, had 2 commitments in Enclosure 2. These commitments involved the E-1 ML12362A045, of the Code of and E-2 items in Enclosure 2 of the Package Federal The first commitment stated the following: "[EGC] will complete licensee letter dated 11 /19/12 and ML123620050) Regulations the walkdown of the fifteen (15) TMI Unit 1 items deferred due to were merged into commitments in 50.54(f) Regarding inaccessibility identified in Table E-1. This commitment due Attachment 12 of the licensee letter Licensee letter Recommendations date was T1 R21 (Fall 2015). The second commitment stated dated 9/16/2013. (Exelon Tracking dated 9/16/13 2.1, 2.3, and 9.3, of the following: "EGC will complete the fifteen (15) remaining No. 1427154-55-00 involved the E-1 (RS-13-213/ the Near-Term supplemental inspections of TMI Unit 1 electrical items as items and 1427154-56-00 involved RA-13-081/ Task Force Review identified in Table E-2." Its due date was T1 R20 (Fall 2013). the E-2 items. These commitments TMl-13-109 of Insights from the were superseded by Exelon Tracking ML13260A083) Fukushima Dai-ichi The licensee letter dated 9/16/13, contained a TMl-specific Nos. 1427154-90-00 and 1427154-Accident, dated evaluation in Attachment 11 and a list of commitments for the 91-00, in that 1427154-90-00 is for Licensee letter 3/12/12 Exelon fleet in Attachment 12 (two were applicable to TMI). It the completion of the inspections dated 3/28/14 (ML12053A340) was indicated in Attachment 11 that all of the walkdown associated with both the 1427154 (RS-14-032, commitment items from the 11/19/12 letter, which included E-1 00 and 1427154-56-00 commitments ML14093A533, NRC Staff and E-2, would be completed by the end of 2014 and that the and 1427154-91-00 was for the Package Assessment, dated items in Table E-2 were complete. Regarding the E-1 items, it submission of the report to the NRC.)

ML14093A527) 5/6/14 also indicated that a new regulatory commitment in Attachment (ML14105A116) 12 replaced the first of the two commitments from the 11 /19/12 Licensee letter RS-14-032, dated letter (Enclosure 2, item 1). This new commitment was item 21 3/28/14, indicated that Commitments in the list of commitments in Attachment 12 and states: "EGC 1 and 2 contained in the 11 /19/12 will complete the inspections of the [TMI] components listed in letter and Commitments. 21 and 22 Attachment 11." The due date was 12/31/13. contained in the 9/16/13 letter were complete. This was also further The licensee letter dated 9/16/13 also contained another new indicated in Section A 1.1 of this letter, TMI commitment in Attachment 12 (item 22) that indicated that which indicated that commitments 1 &

the final seismic walkdown report documenting the results of 2 in Enclosure 2 of RS-12-175 were Attachment 11 inspections would be submitted by 3/31/14. completed (ML14093A533). to MC4724 GL 2004-02 This commitment is for the replacement of the NU KON Open: T1R21 (Fall 2015, 10/28/15) the letter dated insulation installed on the pressurizer with Reflective 5/16/13 Metallic Insulation (RMI). (Exelon Tracking No.

(ML13137A309), 1516774-01)

TABLE 1 Reviewed Licensee Commitments (TMl-1)

(See Note 1)

TMl-1 NRC NRC Source/ Summary of Regulatory Commitment Licensee Implementation Submittal CAC Issuance Status and Tracking No. (if Date No. applicable) as part of the licensee's plan and schedule for responding to Generic Letter 2004-02.

Letter dated MF1459 Letter and Non- This commitment involved TM l's Reactor Internals Inspection Complete.

4/16/2012 Proprietary SE Plan. The commitment requires the licensee to identify the (ML12108A029) (ML14297A411) Reactor Vessel Internals (RVI) components that are within The licensee submitted the requested

s. 4/17 /2013 license renewal scope and to determine if they are included information in the letter dated (ML13108A004) within MRP-227A. If there are components within License 4/17/2013. (This action was to be Renewal scope that weren't included, the licensee shall propose completed by 4/19/13.)

requirements beyond MRP-227A.

(Exelon TrackinQ No. 603573-36-09)

Letter dated MF1459 Letter and Non- This commitment involves TMl's Reactor Internals Inspection Open: The required completion date 4/17/2013 Proprietary SE Plan inaccessible components identified in Table 4-4 of of this commitment was previously (ML13108A004) (ML14297A411) MRP-227-A. The commitment requires the licensee to submit 4/19/2013 and was changed to within

s. 11/06/13 an analysis, schedule, or alternative process justification within one year of the inspection (Fall 2015)

(ML13317A931) one year of the initial inspection (Fall 2017), with a due date of as requested in the licensee letter 12/15118, if the primary component inspection does not meet the dated 4/17/13 as Exelon Tracking No.

acceptance criteria of MRP-227-A. 603573-36-10. The completion date (This action was originally Exelon Tracking No. 603573-36-10 was subsequently changed again to but was closed to Exelon Tracking No. 603573-36-12.) within one year of the inspection (Fall 2017) as requested in the licensee letter dated 11/6/13 and is Exelon Trackino No. 603573-36-12.

Letter dated MF1459 Letter and Non- This commitment involves TMl's Reactor Internals Inspection Open: The required completion date 4/17/2013 Proprietary SE Plan. The commitment requires the licensee to submit Control of this commitment was previously (ML13108A004) (ML14297A411) Rod Guide Tube (CRGT) Spacer Castings and lncore 4/19/2013 and was changed to

s. 11/06/13 Monitoring Instrumentation (IMI) Spider Castings evaluations by 10/30/2014 as requested in the (ML13317A931) 10/3016. The revised commitment also added a vent valve licensee letter dated 4/17/13 as retaining ring analysis that is required to be submitted by Exelon Tracking No. 603573-36-11.

10/30/2016. The completion date was (This action was originally Exelon Tracking No. 603573-36-11 subsequently changed again to but was closed to Exelon Tracking No. 603573-36-13.) 10/30/16 as requested in the licensee letter dated 11/6/13 and is Exelon Trackino No. 603573-36-13. to MC4724 GL 2004-02 Complete strainer head k:Jss testing based on the reduced Complete. The licensee's the letter dated debris k:Jad for TMI, Unit 1. documentation indicated that this

TABLE 1 Reviewed Licensee Commitments (TMl-1)

(See Note 1)

TMl-1 NRC NRC Source/ Summary of Regulatory Commitment Licensee Implementation Submittal CAC Issuance Status and Tracking No. (if Date No. aoolicable) 5/26/13 testing (following pressurizer (ML13137A309), insulation replacement) was as part of the completed in 12/14 and 1/15 and is licensee's plan documented in the "TMI Large Scale and schedule for Head-Loss Test Report" responding to (1142TMIGSl-R2-00), dated 3/23115.

Generic Letter 2004-02. (Exelon Trackinq No. 1516774-02) to MC4724 GL 2004-02 Re-evaluate the strainer debris bypass for TMI, Unit 1. This Open: 7/31/16 the letter dated would include a review of available information for the Enercon 5/26/13 top hat design strainer with a Debris Bypass Eliminator (Exelon Tracking No. 1516774-03)

(ML13137A309), installed and/or performance of a site-specific debris bypass as part of the test licensee's plan and schedule for responding to Generic Letter 2004-02. to MC4724 GL 2004-02 EGC will submit a final updated supplemental response to Open: 6/1/17 the letter dated support closure of GL 2004-02 for TMI, Unit 1.

5/26/13 (Exelon Tracking No. 1516774-04)

(ML13137A309),

as part of the licensee's plan and schedule for responding to Generic Letter 2004-02.

RAI response MF4749 Amendment No. This commitment involves the Cyber Security Plan (CSP). By Open: 12/31/17. A'$ noted in the SE, letter dated 275, letter dated 8/10/11 (ML111861341 ), the NRC staff issued fleet these actions were elevated from 3/31/14 (public) dated 8/10/11 amendments that approved the CSP and implementation commitments to obligations. The (ML110940225) (ML111861341) schedule for TMI and other plants. The approved schedule licensee's documentation for Exelon (non-public) stated that Milestone 8 would be completed no later than Tracking No. 1223694-80-00 notes Enclosure Amendment No. 12/31/15, as requested in Enclosure 3 of the licensee letter this and that a change would require (ML110940226) 288, dated 3/31/14. Based upon the requirements in 10 CFR 73.54 NRC approval per 10 CFR 50.90.

dated 7/30/15 and the license amendments, changes to the schedule require Letter dated (ML15153A282) prior NRC approval. In an NRC memorandum dated 10/24113 (Exelon Tracking No. 1223694-80-00) 8/29/14 (ML13295A467), the staff listed criteria to consider when (public)

TABLE 1 Reviewed Licensee Commitments (TMl-1)

(See Note 1)

TMl-1 NRC NRC Source/ Summary of Regulatory Commitment Licensee Implementation Submittal CAC Issuance Status and Tracking No. (if Date No. applicable)

(ML14241A526) evaluating requests to revise the CSP full implementation date (non-public) (i.e., Milestone 8).

(ML14241A525)

By application dated 8/29/14(ML14241A526), the licensee proposed changes that would revise the date (from 12/31 /15 to 12/31 /17) of CSP implementation schedules for Milestone 8 and license conditions for several Exelon plants, including TMI.

As indicated in the NRG SE dated 7/30/15(ML15153A282), the licensee's proposed commitment changes were accepted. Also, as stated in Section 3.3 of the SE: "The CSP implementation schedules are obligations under 10 CFR 73.54 and the associated amendments approving the CSP for each facility. As such, changes to the CSP implementation schedules will require NRG approval in accordance with 10 CFR 50.90. Therefore, the licensee should not be managing the CSP implementation schedules as regulatory commitments."

Letter dated MF4435 Amendment No. The SE does not discuss commitments, but the submittal Closed.

7/10/14 285, satisfies a commitment. In its 7/10114 letter, the license states:

(ML14191A059) dated 6/30/15 "The proposed amendment would modify TS requirements to This submittal closes the licensee Letter dated (ML15121A589) address Generic Letter 2008-01, "Managing Gas Accumulation commitment indicated in the 10/14/08 10/14/08 in Emergency Core Cooling, Decay Heat Removal, and letter.

(ML082880706) Containment Spray Systems," as described in TS Task Force Traveler 523 (TSTF-523), Revision 2, "Generic Letter 2008-01, (Exelon Tracking Nos. 1516774-04, Managing Gas Accumulation." TMI, Unit 1 committed to 1122072-24, 763395-04, 1600914-06, evaluate the resolution of the TS issues with respect to the and 704366-87) elements contained in the TSTF, and submit a license amendment request, if deemed necessary based on the evaluation, within 180 days following NRG approval of fTSTF-523]. This submittal satisfies the commitment."

9/19/14 MF4873 RR-14-01 The licensee's letter dated 9/19/14 contains the commitment. It Open: Prior to plant restart from the (ML14262A002) Concerning states: Fall 2015 outage s.11/19/14 Alternative Root "Inner Diameter (ID) surface breaking flaws greater than 50%

(ML14328A189) Mean Square through-wall and subsurface flaws greater than 50% through- The licensee has actions to perform Depth Sizing wall shall be repaired or evaluated prior to plant restart. an impact review to determine how Requirements, Evaluations shall be submitted to the NRG for review and licensee documents and programs will dated 9/15/15 approval p'rior to plant restart." be affected, perform the repairs or (ML15163A249) evaluations (if necessary), to provide a report to the NRG. (Exelon The SE discusses this commitment, which was elevated to a

TABLE 1 Reviewed Licensee Commitments (TMl-1)

(See Note 1)

TMl-1 NRC NRC Source/ Summary of Regulatory Commitment Licensee Implementation Submittal CAC Issuance Status and Tracking No. (if Date No. applicable) requirement of the relief request. It was imposed as part of the Tracking Nos. include 2567708-01 alternative in accordance with 10 CFR 50.55a(g)(6)(i). and 2567708-02) The licensee's documentation also indicates that it is included in the Core Flood Nozzles examination contingency plans (Exelon Tracking No. 1476721-62-02)

The licensee's documentation states the following:

"The T1 R21 (2015) inspection of the Core Flood Nozzles were completed satisfactorily with no changes from the previous inspection performed in 2009. The flaws were less than 50%

through-wall and acceptable for continued service. No submittal to the NRC is required. This assignment is being moved to 11/30/21 to support the next scheduled inspection of the Core Flood B Nozzle Dissimilar Metal Weld. RR-14-01 remains valid for the 2021 inspection."

The licensee has also indicated that the obligation was incorporated into TMI 04.603, TMl-Unit 1, ISi Program Plan.

2/4/2013 MF0628 Amendment No. This amendment involved the deletion of various reporting Complete.

(ML14084A270) 284, dated requirements from the current TMI TS.

S. 3/24/2014 12/30/14 The 9/26/14 letter has the following commitment: Section 6.4 of the FSAR has been (ML14084A270) (ML14330A300) "Incorporate a description of the Periodic Leak Reduction revised to include the Periodic Leak

s. 9/26/2014 Program into the licensing basis by revising UFSAR Section 6.4, Reduction Program as Section 6.4.6.

(ML14269A351) "Engineered Safeguards Leakage and Radiation Considerations." (Exelon Tracking No. 1235054-10)

The SE states the following:

"Based on the NRC staff's review, the staff finds that the licensee's current proposed amendment only requests the deletion of the Annual Reporting requirement for the NUREG-0737-related Periodic Leak Reduction proQram and that

TABLE 1 Reviewed Licensee Commitments (TMl-1)

(See Note 1)

TMl-1 NRC NRC Source/ Summary of Regulatory Commitment Licensee Implementation Submittal CAC Issuance Status and Tracking No. (if Date No. applicable) the licensee's commitment to the program as was stated by the licensee in its 1/23/81, response to the staff's 50.54(f) letter mentioned above, is not affected by the proposed change.

Furthermore, according to the licensee's response to the RAI, the program will be reflected in its licensing basis by revising UFSAR Section 6.4, 'Engineered Safeguards Leakage and Radiation Considerations.' In addition, the licensee stated that the requirements for the program are currently addressed in its leakage surveillance procedures."

Letter dated MF5564 TMI Closure The licensee has replaced its original commitment. The Open: Within 21 months following 12/22/2014 Evaluation for licensee has now committed to completing the full LBLOCA re- NRC issuance of the final SER for (ML14356A342) Report Pursuant to analysis within 21 months following NRC issuance of the final BAW-10179, Revision 9.

S. 4/6/15 10 CFR 50.46 Safety Evaluation Report (SER) for BAW-10179, Revision 9, (ML15097A125) Requirements and the licensee also stated that it incorporates by reference the TMI 10 CFR Related to Thermal supplement to BAW-10192P-A, Revision 0.

50.46 Report Conductivity Degradation, dated 12/17/2015 (ML15306A503)

Note 1: The scope of the audit includes commitments closed during the previous 3 years and currently open commitments associated with NRC licensing actions (e.g., amendments, relief requests, exemptions, orders) or licensing activities (e.g., bulletins, generic letters). See Audit Report Section 2.1 for further details.

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1)

(See Note 2)

Change Tracking Source Change/Deletion NRC ADAMS No.(s) Notification Accession No.

Exelon Tracking Nos: Exelon letter TMl-13-106 The Sodium Hydroxide Tank (BS-T-2) Yes. Additionally, this was evaluated ML13260A079 603573-15-04, dated 9/12/13, Revision to was removed from the Above Ground in NRG License Renewal 603573-15-07, and License Renewal Commitment Steel Tanks Aging Management Commitments Inspection Report 603573-15-21 Relating to the Above Ground Program scope and the visual 05000289/2014008(ML14101A286).

Steel Tanks Aging inspection was added to the scope of This inspection report states the Management Program the External Surfaces Monitoring following:

Program. There were no safety "In a letter dated September 12, issues identified as a result of this 2013, Exelon informed the NRG the change. Sodium Hydroxide Tank is no longer used and the visual inspection would be performed as part of the External Surfaces Monitoring Program. The inspectors concluded Exelon was correctly applying the commitment management process stipulated in NEI 99-04 [Revision O], "Guidelines for Managing NRG Commitment Changes," (ML0036800880) when informing the NRG about this change."

Attachment 2

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1)

(See Note 2)

Change Tracking Source Change/Deletion NRC ADAMS No.(s) Notification Accession No.

Commitment Change Three Mile Island Nuclear The biennial revision report Yes. The report also provides a ML14106A020 Tracking No. Station, Unit 1 - Biennial 10 documents Licensing Letter 6710 justification for this change and no 13-01 CFR 50.59 and Commitment 2096 Attachment 1, "GL 89-013: safety issues were identified, as Revision Report for 2012 and Revised Response - Service Water confirmed by the licensee's Exelon Tracking No. 2013(ML14106A020) System Problems Affecting Safety documentation for Commitment 1122072-01 Related Equipment," as the letter Change Tracking No. 13-01.

GL 89-013 source. The following is stated in the revision report as the nature of the (The licensee also previously commitment: "The Emergency documented an error in Incident Cooling Coils will be subject to a Report (IR) 2449863 for a related GL combination of visual inspections and 89-013 commitment associated with trending. Visual inspection of the air this tracking number as well, in which side and monitoring of air and water a Control Building Chiller frequency flows will occur each outage." The was changed out of process. It was revision report indicates that this changed back to the correct commitment was changed to frequency as a result of an monitoring of air flows every other evaluation. This is discussed in outage per Commitment Change Section 2.4 of this report.)

Evaluation Form 13-01.

Commitment Change Three Mile Island Nuclear The letter documents NUREG-1928 Yes. It was provided in the biennial ML14106A020 Tracking No. Station, Unit 1 - Biennial 10 as the letter source. report to the NRC.

13-02 CFR 50.59 and Commitment The revision report indicates that this Revision Report for 2012 and commitment was revised to have the Exelon Tracking No. 2013 (ML14106A020) TMI UFSAR match TMl's SER 603573-11 (NUREG-1928), which the licensee considered to be consistent with the GALL (NUREG-1801, Rev. 2).

Exelon Tracking No. Revision to Exelon Generation As one of the methods for Yes. The NRC was notified by the ML14287A659 1362747-55-00 Company, LLC Commitment maintaining offsite communications, indicated letter. (non-public)

Relating to Emergency Exelon committed to purchasing Communications Aspects of satellite communications trailers with Recommendation 9.3 of the cellular phones for several plants in Near-Term Task Force Review its fleet. This commitment was of Insights from the Fukushima revised such that Exelon will provide Dai-ichi Accident (licensee the sites with satellite dish letter dated 10/14/14, communication systems consisting of ML14287A659) portable and fixed elements.

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1)

(See Note 2)

Change Tracking Source Change/Deletion NRC ADAMS No.(s) Notification Accession No.

Exelon Tracking No: Inspection Plan for Reactor These two commitments involve Yes. They both previously had a due ML13317A931 603573-36-12 Internals TMl's Reactor Internals Inspection date of 4/19/13 but the licensee (formerly 603573 Plan and had extensions to the due requested that both of their dates be

10) Licensee letter, dated 4/17/13 dates. One commitment was changed in a letter dated 4/17/13 and (ML13108A004) regarding inaccessible components subsequently in a letter dated Exelon Tracking No: s. 11/06/13 identified in Table 4-4 of MRP-227-A 11/6/2013.

603573-36-13 (ML13317A931) and requires the licensee to submit (formerly 603573 an analysis, schedule, or alternative

11) process justification within one year of the initial inspection (Fall 2017),

with a due date of 12/15/18, if the primary component inspection does not meet the acceptance criteria of MRP-227-A. The other requires the licensee to submit Control Rod Guide Tube (CRGT) Spacer Castings and lncore Monitoring Instrumentation (IMI) Spider Castings evaluations by 10/30/16.

Exelon Tracking No. "Clarification of Commitment This letter provided clarification Yes. The license also stated: ML15254A045 1516774-01 Regarding Resolution of regarding the following commitment "Preliminary debris analyses and Generic Letter 2004-02", letter in Attachment 2 to the letter to the strainer test results indicate that the from the licensee to the NRC, NRC dated 5/26/13(ML13137A309), reduction in fibrous debris due to the dated 9/10/15 (ML15254A045) as part of the licensee's plan and removal of approximately 80% of the schedule for responding to Generic pressurizer NUKON insulation will be Letter 2004-02: adequate with respect to ECCS "Replace the Nukon insulation pump NPSH concerns. This currently installed on the pressurizer reduction in NUKON insulation will with Reflective Metallic Insulation also reduce the quantity of fibrous (RMI) for TMI, Unit 1." debris bypassing the strainer."

Per the licensee, this was a "one-time action with a committed date of the T1 R21 Refueling Outage in the fall of 2015."

The licensee indicated that it planned to replace "approximately 80% of the Nukon insulation on the pressurizer" and that it did not anticipate the need

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1)

(See Note 2)

Change Tracking Source Change/Deletion NRC ADAMS No.(s) Notification Accession No.

to remove more NUKON insulation in the Reactor Buildina.

Exelon Tracking No. Fleet Cyber Security Milestone By application dated 8/29/14 Yes. As indicated in the NRG staffs ML14241A526 1223694-80 8 Amendment No. 288. (ML14241A526), the licensee SE dated 7/30/15(ML15153A282),

proposed changes that would revise the licensee's proposed revisions to Licensee letter, dated 8/29/14 the date (from 12/31/15 to 12/31/17) the commitments were accepted.

(The non-proprietary version is of regulatory commitments for the The elevated commitments should be ML14241A526.) TMI CSP implementation schedules managed as obligations for which and Milestone 8, which involves the changes will require NRG approval.

full implementation of the CSP. The licensee indicated in its application The licensee's documentation notes that the revised dated would allow this and that a change would require EGG to align its fleet to a common NRG approval per 10 CFR 50.90.

implementation schedule, complete assessments, and implement the resulting design modifications. The licensee provided the proposed revision to the TMI cyber security regulatory commitment related to the Milestone 8 completion date in Attachment 3 and the proposed revision to the TMI cyber security regulatory commitment related to the -

CSP implementation schedule.

Commitment Change NUREG-1928 This commitment involves UFSAR The licensee's documentation NIA Tracking No. 14-01 Appendix A, Section A.3.1.2, indicates that the NRG will be notified Exelon Tracking No. "Concrete Containment Tendon in the next annual Commitment 603573-38 Prestress Aging Management Change Summary Report or UFSAR Program." The commitment revision Update. There is no identified safety allows for the revision of the concern associated with this change.

commitment such that it replaces the reference to the 1992 Edition of the ASME Boiler and Pressure Vessel Code,Section XI (ASME B&PV Code) with a reference to the ASME B&PV Code of record in the current revision of the TMI ISi Program Plan, which eliminates the need for future

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1)

(See Note 2)

Change Tracking Source Change/Deletion NRC ADAMS No.(s) Notification Accession No.

commitment revisions based upon code vear revisions.

Commitment Change IEB 80-15, Possible Loss of Commitment Change Tracking No. The licensee's documentation N/A Tracking No. 14-04 Emergency Notification 14-04 is for the closure of this indicates that the NRG will be notified Exelon Tracking No. System with LOOP commitment. The licensee's in the next annual Commitment 1122072-39 documentation provided the Change Summary Report or UFSAR justification that the original Update.

commitment to notify the NRG Operations Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the discovery of an Emergency Notification System (ENS) extension to be inoperable is now covered by 10 CFR 50.72(b)(3)(xiii). The document also indicates that compliance with 10 CFR 50.72 is provided by Exelon procedure EP-AA-121.

Commitment Change NRG Bulletin 2005-02, Attachment 11 of the licensee letter The licensee's documentation N/A Tracking No. 14-08 "Emergency Preparedness dated 8/17/05 provided a commitment indicates that the NRG will be notified and Response Actions for to revise the Emergency Plan to in the next annual Commitment Exelon Tracking No. Security-Based Events" incorporate drills and exercises based Change Summary Report or UFSAR 1122072-5710 upon terrorist-based events in Bulletin update. There is no identified safety Letter, dated 8/17/05, "30-day 2005-02 Attachment 6, "Examples of concern associated with this change.

Response to NRG Bulletin Acceptable Changes to Security-2005-02, 'Emergency Related Drill and Exercise Program." The licensee indicated that the Preparedness and Response The licensee's documentation changes for the commitment had Actions for Security-Based indicated that this commitment was been incorporated into Rev 24 of EP-Events" (ML052300145) canceled by the licensee in AA-1000 and that the required December 2014, with the indication commitment actions, which are now NRG SER, dated 12/1/2006 that 10 CFR 50 Appendix E provides an obligation, is currently contained (ML063330535) the information for the drill in Rev 28 of EP-AA-1000, Exelon frequencies. Nuclear Standardized Radiological Emergency Plan, Section N: Drill and Exercise Proi:iram.

Commitment Change Generic Letter 83-28, Generic Letter 83-28 Item 2.1, The licensee tracked the history and NIA Tracking No. 15-01 "Required Actions Based on "Equipment Classification and Vendor closure of this commitment. The (Commitment Change Generic Implications of Salem Interface (Reactor Trip System licensee's documentation indicates Tracking No. 15-01 is ATWS Events" and Generic Components)," was divided into 2 that the NRG will be notified in the for the closure of this Letter 90-03, "Relaxation of oarts (as described in an NRG SER next annual Commitment Change

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1)

(See Note 2)

• Change Tracking Source Change/Deletion NRC ADAMS No.(s) Notification Accession No.

commitment.) Staff Position in Generic Letter dated 8/12/81, and later in GL 90-03), Summary Report or UFSAR Update.

83-28, Item 2.2 Part 2 "Vendor with the Vendor Interface portion Exelon Tracking No. Interface for Safety-Related being subsequently referred to as In the NRC SER dated 8/12/81, the 1122072-57 Components" are applicable to Part 2 and Item 2.2. NRC accepted the response to Part 1 this section. for TMI but rejected the response to Part 2. GL 83-28 relaxed this requirement. A response was provided by letter dated 10/1/90, and an NRC SER dated 10/12/90, accepted the response to Part 2.

Exelon Tracking No. TMI 10 CFR 50.46 30-Day The original commitment submitted in Yes. The NRC evaluation, dated ML15097A125 2428693-01 Report the 12/22/14 letter indicated that 12/17/15 (ML15306A503), stated the Exelon will perform a full LBLOCA following:

Letter, dated 12/22/2014 reanalysis for TMI by 3/31/17, and "The NRC staff determined that this (ML14356A342) that the effects of fuel pellet thermal commitment revision is acceptable as

s. 4/6/15 conductivity degradation (TCD) will it does not affect the outcome of the (ML15097A125) be accounted for by use of a fuel NRC staffs review or the licensee's temperature uncertainty adjustment compliance with the regulations."

factor based on COPERNIC2.

This commitment was superseded by a commitment made in the 3/8/15 letter. The licensee has now committed to completing the full LBLOCA re-analysis within 21 months following NRC issuance of the final SER for BAW-10179, Revision 9, and the licensee also stated that it incorporates by reference the supplement to BAW-10192P-A, Revision 0.

Exelon Tracking Nos. NRC Request for Information These commitments are regarding Yes. Licensee letter RS-14-032 ML13260A083 1427154-55-00 Pursuant to Title 10 of the the Seismic Walkdown Deferred indicated that Regulatory involved the E-1 items Code of Federal Regulations Inspections for TMI. Licensee letter Commitment Nos. 1 and 2 contained and 1427154-56-00 50.54(f) Regarding RS-12-175/TMl-12-161, dated in the 11/19/12 letter, and Regulatory involved the E-2 items. Recommendations 2.1, 2.3, 11/19/12, provided 2 commitments. Commitment Nos. 21 and 22 These commitments and 9.3, of the Near-Term In particular, these commitments contained in the 9/16/13 letter were were superseded by Task Force Review of Insights involved the completion of the complete. This was further Exelon Trackinq Nos. from the Fukushima Dai-ichi deferred walkdown items in Table E-1 discussed in Section A 1.1, which

TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (TMl-1)

(See Note 2)

Change Tracking Source Change/Deletion NRC ADAMS No.(s) Notification Accession No.

1427154-90-00 and Accident, dated 3/12/12 and Table E-2 in the licensee letter indicated that Commitment Nos. 1 1427154-91-00. (ML12053A340) dated 11 /19/12 and were merged into and 2 in Enclosure 2 of RS-12-175 commitments in Attachment 12 of the were completed (ML14093A533).

Licensee letter, dated 11/19/12 licensee letter dated 9/16/13.

(RS-12-175, ML12362A045, Package ML123620050)

Licensee letter, dated 9/16/13 (RS-13-213/ RA-13-081/

TMl-13-109, ML13260A083)

Licensee letter, dated 3/28/14 (RS-14-032, ML14093A533, Package ML14093A527)

Note 2: The scope of this portion of the audit includes verifying that the licensee has established and implemented appropriate administrative controls for modifying or deleting regulatory commitments made to the NRG. The scope includes commitment changes reported to the NRG and commitment changes not reported to the NRG since the previous audit. See Audit Report Section 2.2 for further details.

TABLE 3 Review of NRC License Amendments, Relief Requests, and Exemptions (TMl-1}

(See Note 3)

Application TAC Description NRC Letter Safety Evaluation Discusses Audit Date No. Date Regulatory Commitments? Results (Accession (ADAMS (Yes/No)

No.) Accession No.)

11/7/12 MF0046 RRs PR-01, PR-02, and 8/15/13 No. The SE does not discuss regulatory commitments. No (ML12313A344) ,MF0047 VR-02, Associated with the (ML13227A024) issues.

s.417/13 MF0048 Fifth 10-Year lnservice (ML13108A003) Test Interval 7/6/12 ME9063 (Fleet) TS 5.3.1/6/3/1 Unit Amendment No. No. The SE does not discuss regulatory commitments. No (ML12202A034) (Facility) Staff 280 issues.

Qualifications 6/20/13 (ML13079A372) 10/5/12 ME9788 RR-12-01, Examination of 8/27/13 No. The SE does not discuss regulatory commitments. No (ML12283A252) Certain Pressurizer Relief (ML13227A007) issues.

S. 3/18/13 Nozzle Welds (ML13078A329) 10/18/12 ME9818 RR-12-02, Installation of a 6/10/13 Yes. As stated in the SE: No (ML12292A584) Full Structural Weld (ML13134A467) 'The licensee provided the following commitment in the issues.

s. 1/17113 Overlay on the Lower Cold application dated 10/18/12: 'Exelon Generation Company, (ML13018A248) Leg Letdown Nozzle LLC commits to providing the results of the ultrasonic 3/11/13 Dissimilar Metal Welds examination of the Full Structural Weld Overlay on the TMI, (ML13071A093) and Alloy 600 Safe-End Unit 1 lower cold leg letdown nozzle dissimilar metal welds and Alloy 600 safe-end. The results will include: (1) A list of the indications detected, (2) The disposition of all the indications using the standards of ASME Code Cases N-740-2 and N-770-1, (3) The type and, if possible, nature of the indications. Also included in the results will be a discussion of any repairs to the overlay material.'

The licensee will provide the results within 30 days after the completion of the last UT examination of weld overlays during the fall 2013 TMl-1, T1 R20 refueling outage. The NRC staff reviewed this commitment and finds it acceptable. The NRC staff also concludes that tracking this commitment under the licensee's commitment tracking program is appropriate."

Exelon letter TMl-13-168 (ML13338A431 ), dated 12/3/13, Attachment 3

TABLE 3 Review of NRC License Amendments, Relief Requests and Exemptions (TMl-1)

(See Note 3)

Application TAC Description NRC Letter Safety Evaluation Discusses Audit Date No. Date Regulatory Commitments? Results (Accession (ADAMS (Yes/No)

No.) Accession No.)

discussed the closeout of the commitment and did not contain new commitments. The letter states: "During the recent TMI, Unit 1 refueling outage, the identified welds were successfully overlaid. Ultrasonic examinations of these overlays did not identify any indications. Additionally, there were no repairs to the overlay material. Accordingly, this commitment is complete."

10/18/12 ME9819 RR VR-01, Proposed 8/28/13 No. The SE does not discuss regulatory commitments. No (ML12292A585) Alternative Testing of the (ML13232A051) issues.

s. 3/15/13 Pressurizer Pilot Operated (ML13074A700) Relief Valve 12/14/12 MF0424 Revision of the Pressure Amendment No. No. The SE does not discuss regulatory commitments. No (ML12353A319) MF0425 and Temperature Limit 281 issues.

s. 1/31/13 Curves and the Low 12/13/13 (ML13032A312) Temperature (ML13325A023)

s. 8/13/13 Overpressure Protection Exemption (ML13232A235) Limits) 12/13/13 (ML13324A086, ML13324A089)

TABLE 3 Review of NRC License Amendments, Relief Requests and Exemptions (TMl-1)

(See Note 3)

Application TAC Description NRC Letter Safety Evaluation Discusses Audit Date No. Date Regulatory Commitments? Results (Accession (ADAMS (Yes/No)

No.) Accession No.)

2/4/13 MF0628 Delete Reporting Amendment No. Yes. No (ML13037A051) Requirements 284 The 9/26/14 letter has the following commitment. issues.

s. 3/24/14 12/30/14 "Incorporate a description of the Periodic Leak Reduction (ML14084A270) (ML14330A300) Program into the licensing basis by revising UFSAR 9/26/14 Section 6.4, "Engineered Safeguards Leakage and (ML14269A351) Radiation Considerations."

The SE states the following:

"Based on the NRC staffs review, the staff finds that the licensee's current proposed amendment only requests the deletion of the Annual Reporting requirement for the NUREG-0737-related Periodic Leak Reduction program and that the licensee's commitment to the program as was stated by the licensee in its 1/23/81, response to the staffs 50.54(f) letter mentioned above, is not affected by the proposed change. Furthermore, according to the licensee's response to the RAI, the program will be reflected in its licensing basis by revising UFSAR Section 6.4, 'Engineered Safeguards Leakage and Radiation Considerations.' In addition, the licensee stated that the requirements for the program are currently addressed in its leakaqe surveillance procedures."

2/27/13 MF4034 RR to Use Code Case 7/31/14 No. There were no regulatory commitments contained in No (ML13059A498) N-786 for the Repair of (ML141758593) the licensee's submittals. The licensee submittals issues.

S. 6/24/13 ASME Class 2 & 3 Piping indicated that there were no regulatory commitments but it (ML13176A143) incorrectly refers to requirements of the relief request as a 12/12113 commitment. The NRC staff discussed this with the (ML13351A410) licensee during the onsite portion of the audit to confirm 4/28/14 that the licensee was aware of the need for this clarification (ML14119A289) in its submittals as well as NRC expectations regarding commitments and obligations identification and manaqement.

9/25/13 MF2651 RR to Use a Later Edition 7/18/14 No. The SE does not discuss regulatory commitments. No (ML13270A197) and Addenda of the ASME (ML14176A748) issues.

B&PV Code,Section XI

TABLE 3 Review of NRC License Amendments, Relief Requests and Exemptions (TMl-1)

(See Note 3)

Application TAC Description NRC Letter Safety Evaluation Discusses Audit Date No. Date Regulatory Commitments? Results (Accession (ADAMS (Yes/No)

No.) Accession No.)

10/30/13 MF3009 Emergency Response Amendment No. No. The SE does not discuss regulatory commitments. No (ML133048168) MF3010 Organization (ERO) 283 issues.

s. 6/13/14 Requalification Training 12/24/14 (ML14167A226) Freouency (Fleet) (ML14226A940) 5/7/14 MF4110 TSTF-522 Revise Amendment No. No. The SE does not discuss regulatory commitments. No (ML14127A424) Ventilation System SRs 282 issues.

10/14/14 (ML14240A348) 7/10/14 MF4435 TSTF-523 Revise TS & Amendment No. The SE does not discuss commitments, but the submittal No (ML14191A059) SRs for GL-2008-01, 285 satisfies a licensee commitment as discussed in Table 1. issues.

s. 517/15 Managing Gas 6/30/15 (ML15127A537) Accumulation (ML15121A589) 10/30/14 MF5108 Modify RCS Pressure Amendment No. There were no regulatory commitments contained in the No (ML14304A083) Isolation Valve TS 286 licensee's submittal, but the SE references a commitment issues.

s. 6/10/15 Allowable Limits 7/28/15 as background information.

(ML15161A333) (ML15090A584)

The SE indicates that TMl-1 responded to Generic Letter 80-14 and committed valves CF-VF5A/B and DH-V22A/B to specified maximum allowable leakage rate criteria. As noted in the SE, this leakage criteria was revised. The SE states the following: "The NRC staff completed a review of the licensee's system configuration, installed components, inservice testing program plan, and the maintenance history. The review confirms that pressure relief valves are installed and are capable of meeting the revised leakage criteria. The NRC staff also confirmed that the valves are qualified and tested to the requirements of the ASME OM Code and have an acceptable maintenance leakage historv."

8/29/14 MF4749 Fleet Cyber Security Amendment No. By application dated 8/29/14 (ADAMS Accession No. No (non-proprietary) Milestone 8 288 ML14241A526), the licensee proposed changes that would issues.

(ML14241A526) 7/30/15 revise the date (from 12/31 /15 to 12/31 /17) of CSP (proprietary) (ML15153A282) implementation schedules for Milestone 8 and the existing (ML14241A525) license conditions in the facility operating licenses for several Exelon plants, including TMI. Attachments 3 and 4 of the application contained revisions to regulatorv

TABLE 3 Review of NRC License Amendments, Relief Requests and Exemptions (TMl-1)

(See Note 3)

Application TAC Description NRC Letter Safety Evaluation Discusses Audit Date No. Date Regulatory Commitments? Results (Accession (ADAMS (Yes/No)

No.) Accession No.)

commitments for TMI that are regarding CSP implementation schedule and implementation of Safety, Security, and Emergency Planning (SSEP) functions.

As indicated in the NRC staff's SE (dated 7/30/15), the licensee's proposed changes to the commitments were approved. Also. as stated in Section 3.3 of the SE: "The CSP implementation schedules are obligations under 10 CFR 73.54 and the associated amendments approving the CSP for each facility. As such, changes to the CSP implementation schedules will require NRC approval in accordance with 10 CFR 50.90. Therefore, the licensee should not be managing the CSP implementation schedules as regulatory commitments."

The licensee's documentation notes this and that a change would require NRC aooroval per 10 CFR 50.90.

5/30/14 MF4250 Fleet - EAL Scheme re Amendment No. No. The SE does not discuss regulatory commitments. No (ML14164A054) NEI 99-01, Rev. 6 287 issues.

s. 3/2/15 7/28/15 (ML15071A118) (ML15141A058) 9/19/14 MF4873 RR-14-01 Concerning 9/15/15 Yes. The SE discusses a commitment that was elevated to No (ML14262A002) Alternative Root Mean (ML15163A249) a requirement of the relief request. It was imposed as part issues.

s. 11/19/14 Square Depth Sizing of the alternative in accordance with (ML14328A189) Requirements 10 CFR 50.55a(a)(6)(i).

7/23/15 MF6504 Temporary Restoration of Amendment No. No. The SE does not discuss regulatory commitments. No (ML15204A843) the Borated Water Storage 289 issues.

s. 7/28/15 Tank Cleanup and 10/1/15 (ML15209A960) Recirculation Operation (ML15225A158)

s. 8/18/15 ML15230A533

s. 8/25/15 (ML15237A417)

Note 3: The scope of this portion of the audit includes a review of the license amendments. relief requests. and exemptions issued since the previous TMl-1 audit. The intent of the review is to determine the extent to which commitments have been misapplied (e.g .. commitment relied on by NRC staff rather than elevating it to an obligation or incorporating the commitment into a mandated licensing basis document). See Audit Report Section 2.3 for more details.

ML15338A193 OFFICE DORL/LPL 1-2/PM DORL/LPL 1-2/LA DORL/LPL 1-2/BC DORL/LPL 1-2/PM NAME RGladney LRonewicz DBroaddus RGladney DATE 2/29/2016 2/29/2016 4/25/2016 4/26/2016