ML072480261

Audit of the Licensee'S Management of Regulatory Commitments (TAC Nos. MD6133 and MD6134)

ML072480261
Person / Time
Site:	Calvert Cliffs
Issue date:	09/18/2007
From:	Pickett D NRC/NRR/ADRO/DORL/LPLI-1
To:	Spina J Calvert Cliffs
Pickett D, NRR/DORL, 415-1364
References
TAC MD6133, TAC MD6134
Download: ML072480261 (10)

Text

September 18, 2007Mr. James A. Spina, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDITOF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)

Dear Mr. Spina:

An audit of the commitment management program was performed at the Calvert Cliffs NuclearPower Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes. Details of the audit are described in the enclosed audit report. The NRC staff appreciates theresources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.Sincerely,/RA/Douglas V. Pickett, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-317 and 50-318

Enclosure:

As statedcc w/encl: See next page September 18, 2007Mr. James A. Spina, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDITOF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)

Dear Mr. Spina:

An audit of the commitment management program was performed at the Calvert Cliffs NuclearPower Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes. Details of the audit are described in the enclosed audit report. The NRC staff appreciates theresources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.Sincerely,/RA/Douglas V. Pickett, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-317 and 50-318

Enclosure:

As statedcc w/encl: See next page DistributionPUBLICLPL1-1RidsNrrDorlLpl1-1RidsNrrPMDPickettRidsNrrLASLittleRidsOgcRpRidsAcrsAcnwMailCenterRidsRgn1MailCenterAccession: ML072480261OFFICELPLI-1LPLl-1/PMLPLI-1/LALPLI-1/BCNAMEDWoodyattDPickettSLittleMKowalDATE09 /13/ 0709 /13/ 0709 /12/ 0709 /18/ 07OFFICIAL RECORD COPY Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:

Mr. Michael J. Wallace, PresidentConstellation Generation Group 750 East Pratt Street Baltimore, MD 21202Mr. John M. HeffleySenior Vice President and Chief Nuclear Officer Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 310 Annapolis, MD 21401PresidentCalvert County Board of Commissioners 175 Main Street Prince Frederick, MD 20678Mr. Carey Fleming, EsquireSr. Counsel - Nuclear Generation Constellation Generation Group, LLC 750 East Pratt Street, 17 th floorBaltimore, MD 21202Mr. Jay S. GainesDirector, Licensing Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685Mr. R. I. McLean, ManagerNuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)

Tawes State Office Building Annapolis, MD 21401Regional Administrator, Region IU.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406Ms. Kristen A. Burger, EsquireMaryland People's Counsel 6 St. Paul Centre Suite 2102 Baltimore, MD 21202-1631Ms. Patricia T. Birnie, EsquireCo-Director Maryland Safe Energy Coalition P.O. Box 33111 Baltimore, MD 21218Mr. Roy HickokNRC Technical Training Center 5700 Brainerd Road Chattanooga, TN 37411-4017 EnclosureAUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)REGULATORY COMMITMENTS MADE BY THE LICENSEE TOTHE NUCLEAR REGULATORY COMMISSION (NRC)CALVERT CLIFFS NUCLEAR POWER PLANT, INC.CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2DOCKET NOS. 50-317 AND 50-31

81.0 INTRODUCTION

In SECY-00-045, "Acceptance of NEI [Nuclear Energy Institute] 99-04, 'Guidelines forManaging NRC Commitments,'" dated February 22, 2000, the NRC staff informed the Commission that it had found that NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments made by power reactor licensees to the NRC. A "regulatory commitment," as defined in NEI 99-04, is 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.NEI 99-04 provides the NRC staff and its stakeholders with a common reference for handlingregulatory commitments made by the licensees for commercial nuclear reactors to the NRC staff. According to NEI 99-04, a "regulatory commitment" is 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. Internal NRC staff guidance directs 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.)." The audit is to be performed every 3 years. 2.0AUDIT PROCEDURE AND RESULTSSince no audit was performed before the issuance of NEI 99-04, the NRC staff defined theperiod covered by this audit to go back approximately 3 years. The audit was performed at the Calvert Cliffs Nuclear Power Plant Licensing Office in Lusby, Maryland, on August 14, 2007.2.1Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented thosecommitments made to the NRC as part of past licensing activities. The staff examined a sample of completed commitments to ensure that they were implemented in a manner that satisfied both the action committed to and the overall intent of the commitment. The licenseeviews a commitment as any action they agree to perform. The staff's findings are summarized in the attached table.2.2Verification of Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensee's performance related to implementingcontrols for modifying or deleting commitments made to the NRC. The staff examined the licensee's commitment tracking system and the NRC commitment management procedures.When the licensee incorporates commitments into plant procedures, the licensee includes areference code to the document originating the commitment. If the licensee changes or deletes a commitment, the licensee's procedure directs their staff to use the Commitment Evaluation Form, incorporated from NEI 99-04 guidance.The licensee submits Changes to Commitments Made to the NRC as an attachment to theannual revision of the Updated Final Safety Analysis Report. This attachment describes theoriginal commitment, describes the change, and provides the justification for the change. The licensee has submitted 1 change notification to the NRC in the past 3 years. The commitment changes were submitted to the NRC by letter dated September 8, 2005. The NRC staff also examined a change letter dated December 19, 2002. The staff determined that the commitment changes were made in accordance with the licensee's programs and procedures.

The licensee's technical evaluations adequately justified the change, and the NRC was informed of commitment changes that have safety or regulatory significance. The licensee's procedures for changing commitments follow the guidance of NEI 99-04.

3.0CONCLUSION

Based on the above, the NRC staff concludes that; (1) the licensee had implemented or istracking for future implementation regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDITBetty DoughPatricia Furio Craig NeymanPrincipal Contributor: Diana Woodyatt, NRR Date: September 18, 2007

Attachment:

As stated Attachment-1-AUDIT OF CONSTELLATION ENERGY MANAGEMENT OFREGULATORY COMMITMENTSAT CALVERT CLIFFS NUCLEAR POWER PLANTPERFORMED AUGUST 14, 2007LIST OF COMMITMENTS INCLUDED IN AUDITItem No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure1CT20040003109/21/2004In order to verify that interim compensatorymeasures (ICM) for independent spent fuel storage installations (ISFSI) remain unchanged, the licensee must respond to the NRC in writing within 10 days of receipt of 09/10/2004 letter from NRC;

Subject:

Implementation Status of Independent Spent Fuel Storage Installation Interim Compensatory Measures (TAC Nos.

MC2900 and MC2901) ClosedNuclear Security reviewed theISFSI ICMs and determined that the activities found in the Security Plan and Contingency Plan for the ISFSI did not decrease the effectiveness of the ISFSI ICMs. A letter dated 09/27/2004 was sent to the NRC stating the effectiveness of the ISFSI ICMs.2CT20040003309/28/2004Amendment Nos. 269 and 245 removeTechnical Specification (TS) 5.5.3, "Post-Accident Sampling System," from Calvert Cliffs Nuclear Power Plant Unit Nos. 1 and 2, respectively. Commitment is to review safety evaluation report deleting TS 5.5.3 and check the TS for accuracy.ClosedTwo groups within the CalvertCliffs organization reviewed the safety evaluation and determined that the TS were

correct. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure3CT20040004112/17/2004Determine participants for January 14, 2005NRC workshop on enhancing reactor mitigative measure and strategies. Email, to the NRC, the name, title and organization for participants granted unescorted access and the name, title, organization, date of birth, social security number, and finger print checks for all participants that have not been granted unescorted access. Inform NRC if participants need special accommodations December 27, 2004.ClosedThe names, titles,organizations, and details of participants were sent to the NRC. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure4CT20050000802/22/2005Relief request - Weld overlay and alternativetechniques, Third Ten-Year Inservice Inspection Interval. (1) Demonstrate production weld within heat sink temperature limits by testing on a conservative mockup. (2) Regularly monitor production welds with contact pyrometers and/or temperature indicating crayons, record. (3) Use mockups to identify first weld layer where a 24% minimum Cr content is achieved over the base materials.

(4) Production structural overlay performed with same welding parameters as mockups.

(5) Ultrasonic inspection of weld overlay.

(6) Monitor process temperatures, provide manual record, calibrate pyrometers in accordance with Measuring and Test Equipment (M&TE) program. (7) Apply 360° full structural weld overlay to control crack growth, maintain weld integrity.ClosedParts 1, 3, 4, and 5 werediscontinued from commitment.

Part 2 was completed by chemical analysis by x-ray fluorescence performed on overlay layers on mockups; an analysis was performed above ferritic, Alloy 82/182, and austenitic stainless steel base metals; the second layer contained a Cr content greater than 24% and therefore credited toward design thickness. Part 6 was closed by documenting the temperatures taken during installation of the weld overlays and attaching a copy of the M&TE calibration data. Part 7 was closed by documenting the installation of a 360° weld overlay on the hot leg drain nozzle and the cold leg letdown nozzle. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure5CT20050001303/13/2005Request for Approval of a Common QualityAssurance (QA) Program for Constellation Generation Group, LLC. - Review the Calvert Cliffs QA Policy and the QA Topical Report to ensure all commitments to Regulatory Guides and standards that are in the Calvert Cliffs QA Policy and not in the QA Topical Report are relocated to the Updated Final Safety Analysis Report.ClosedThe request for approval of acommon QA Program was withdrawn 08/24/2005 in a letter from the licensee.6CT20050002005/20/2005Review Draft Regulatory Guide DG-8029,proposed Revision 2 to Regulatory Guide 8.7, " Instructions for Recording and Reporting Occupational Radiation Dose Data" and provided comments to the NRC via http://www.nrc.gov/what-we-do/regulatory/rulemaking.html.ClosedCalvert Cliffs Health Physicsdepartment reviewed the draft guide and concluded that the draft has no new requirements and was created for the purpose of providing greater clarification to the user when recording and reporting radiation dose data and there are no comments for the NRC.7CT20050002808/23/2005Provide input and respond to NRC Requestfor Additional Information regarding requirements related to positive reactivity additions from NRC letter dated 08/19/2005.ClosedOn 09/16/2005 Calvert Cliffssubmitted a letter to the NRC with their response to the request for additional information. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure8CT20050003210/04/2005Underwater welding of heated junctionthermocouple (HJTC) probe holders.

Perform mockup testing for welders using similar materials and under similar conditions as the production welds. Perform inspection of sample welds to the same requirements as the production welds.

Verify that the weld procedure specification approved for use in welding HJTC probe holders to the upper guide structure (UGS) plate is qualified with tensile and bend tests in accordance with ASME Section IX, and the additional requirements of Code Case N-516-2. Verify complete within schedule.ClosedWelder qualification completedthrough mockup testing and inspections performed as specified. A work order was developed to perform HJTC probe holders to the UGS plate in compliance with the requirements of ASME Section IX and Code Case N-516-G-3, Revision 2. 9CT20050003811/07/2005Review NRC Regulatory Issue Summary(RIS) 2005-25, "Clarification of NRC Guidelines for Control of Heavy Loads," for applicability and program changes. ClosedThe RIS was reviewed forapplicability to the Calvert Cliffs Reactor Vessel Head Replacement Project and the Calvert Cliffs Load Handling Program. The licensee determined that no changes were required to the Reactor Vessel Head Replacement Project or the Load Handling Program as a result of the RIS.