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{{#Wiki_filter:UNITED NUCLEAR REGULATORY  
{{#Wiki_filter:UNITED STATES
WASHINGTON, D.C. 20555-0001  
                              NUCLEAR REGULATORY COMMISSION
February 27, 2009 Mr. Charles G.  
                                      WASHINGTON, D.C. 20555-0001
Pardee President  
                                            February 27, 2009
and Chief Nuclear Officer Exelon Generation  
Mr. Charles G. Pardee
Company 4300 Winfield Road Warrenville, IL 60555 SUB..OYSTER CREEK NUCLEAR GENERATING  
President and Chief Nuclear Officer
STATION (OCNGS) -AUDIT OF EXELON'S MANAGEMENT  
Exelon Generation Company
OF REGULATORY  
4300 Winfield Road
COMMITMENTS (TAC NO. ME0362) Dear Mr. Pardee:  
Warrenville, IL 60555
In Regulatory  
SUB..IECT        OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF
Issue Summary 2000-17, "Managing  
                EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.
Regulatory  
                ME0362)
Commitments Made by Power  
Dear Mr. Pardee:
Reactor Licensees to the NRC Staff," dated  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power
September  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory
21,2000, the U. S.  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,
Nuclear Regulatory  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for
Commission (NRC) informed licensees that the Nuclear Energy Institute  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or
document NEI 99-04, "Guidelines  
similar administrative controls to ensure that regulatory commitments are implemented and that
for Managing NRC Commitment  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the
Changes," contains acceptable  
NRC.
guidance for controlling  
The NRC Office of Nuclear Reactor Requtation has instructed its staff to perform an audit of
regulatory  
licensees' commitment management programs once every 3 years to determine whether the
commitments  
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory
and encouraged  
commitments are being effectively implemented.
licensees to use the NEI  
An audit of OCNGS's commitment management program was performed during January and
guidance or similar administrative  
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,
controls to ensure that regulatory  
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
commitments  
acceptable program for implementing and managing NRC commitments. Details of the audit
are implemented and that changes to the regulatory  
are set forth in the enclosed audit report.
commitments  
                                              G. dward Miller, Project Man ger
are evaluated and, when  
                                              Plant Licensing Branch 1-2
appropriate, reported to the NRC. The NRC Office of  
                                              Division of Operating Reactor Licensing
Nuclear Reactor Requtation has  
                                              Office of Nuclear Reactor Regulation
instructed  
Docket No. 50-219
its staff to perform an  
Enclosure: Audit Report
audit of licensees'  
cc w/encl: Distribution via ListServ
commitment  
 
management  
                                                UNITED STATES
programs once every 3 years to determine  
                                NUCLEAR REGULATORY COMMISSION
whether the licensees'  
                                          WASHINGTON, D.C. 20555-0001
programs are consistent with the industry guidance in NEI 99-04, and  
          AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION
that regulatory  
                  LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS
commitments are being  
                      OYSTER CREEK NUCLEAR GENERATING STATION
effectively  
                                          DOCKET NO. 50-219
implemented. An audit of  
1.0     INTRODUCTION AND BACKGROUND
OCNGS's commitment  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power
management program was  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory
performed  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,
during January and February 2009, including  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for
activities  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or
at Exelon's office in  
similar administrative controls to ensure that regulatory commitments are implemented and that
Kennett Square, PA on February 24, 2009. The NRC  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the
staff concludes, based on the audit, that OCNGS has implemented  
NRC.
an acceptable program for  
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit
implementing  
of licensees' commitment management programs once every 3 years to determine whether the
and managing NRC commitments. Details of the audit are set forth in the  
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory
enclosed audit report. G. dward Miller, Project Man ger Plant Licensing  
commitments are being effectively implemented.
Branch 1-2 Division of  
NEI-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action
Operating  
agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.
Reactor Licensing Office of  
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment
Nuclear Reactor Regulation  
management program by assessing the adequacy of the licensee's implementation of a sample
Docket No. 50-219 Enclosure:  
of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions,
Audit Report cc w/encl: Distribution  
etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
via ListServ
2.0     AUDIT PROCEDURE AND RESULTS
UNITED NUCLEAR REGULATORY  
An audit of the Oyster Creek Nuclear Generating Station (OCNGS) commitment management
WASHINGTON, D.C. 20555-0001  
program was performed at the NRC Headquarters using documentation provided by the
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION  
licensee and at the licensee's Kennett Square office during the period of January and February
LICENSEE MANAGEMENT  
2009. The audit reviewed commitments made since the previous audit in January 2004. The
OF REGULATORY  
audit consisted of two major parts: (1) verification of the licensee's implementation of NRC
COMMITMENTS  
commitments that have been completed, and (2) verification of the licensee's program for
OYSTER CREEK NUCLEAR GENERATING  
managing changes to NRC commitments.
STATION DOCKET NO. 50-219 1.0 INTRODUCTION  
                                                                                            Enclosure
AND BACKGROUND  
 
In Regulatory  
                                                  -2
Issue Summary 2000-17, "Managing  
2.1      Verification of Licensee's Implementation of NRC Commitments
Regulatory  
The primary focus of this part of the audit is to confirm that the licensee has implemented
Commitments  
commitments made to the NRC as part of past licensing actions/activities. For commitments not
Made by Power Reactor Licensees to the NRC Staff," dated September  
yet implemented, the NRC staff determines whether they have been captured in an effective
21,2000, the U. S.  
program for future implementation.
Nuclear Regulatory  
2.1.1    Audit Scope
Commission (NRC) informed licensees that the Nuclear Energy Institute  
The audit addressed a sample of commitments made during the review period. The audit
document NEI 99-04, "Guidelines  
focused on regulatory commitments (as defined above) made in writing to the NRC as a result
for Managing NRC Commitment  
of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins,
Changes," contains acceptable  
generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices
guidance for controlling  
of Violation may be included in the sample, but the review will be limited to verification of
regulatory  
restoration of compliance, not the specific methods used. Before the audit, the NRC staff
commitments  
searched the Agencywide Documents Access and Management System (ADAMS) for the
and encouraged  
licensee's submittals since the last audit and selected a representative sample for verification.
licensees to use the NEI  
The audit excluded the following types of commitments that are internal to licensee processes:
guidance or similar administrative  
(1)      Commitments made on the licensee's own initiative among internal organizational
controls to ensure that regulatory  
        components. (Note: the internal self-assessment and subsequent transition to the
commitments  
        Exelon Passport program was audited as an indicator of the commitment to the
are implemented and that changes to the regulatory  
        process.)
commitments  
(2)      Commitments that pertain to milestones of licensing actions/activities (e.g., respond to
are evaluated  
        an NRC request for additional information by a certain date). Fulfillment of these
and, when appropriate, reported to the NRC. The NRC Office of Nuclear Reactor Regulation (NRR) has instructed  
        commitments was indicated by the fact that the subject licensing action/activity was
its staff to perform an audit of licensees'  
        completed.
commitment  
(3)      Commitments made as an internal reminder to take actions to comply with existing
management  
        regulatory requirements such as regulations, technical specifications, and updated final
programs once every 3 years to determine  
        safety analysis reports. Fulfillment of these commitments was indicated by the licensee
whether the licensees'  
        having taken timely action in accordance with the subject requirements.
programs are consistent with the industry guidance in NEI 99-04, and that regulatory  
2.1.2    Audit Results
commitments are being  
Table 1 contains a list of those documents that were selected for additional review during this
effectively  
audit.
implemented.  
The NRC staff found that the licensee's commitment tracking program had captured all the
NEI-99-04  
regulatory commitments that were identified by the NRC staff before the audit. The NRC staff
defines a "regulatory  
also reviewed plant procedures, assessment recommendations, work orders, corrective actions,
commitment" as an explicit statement  
training, qualification certifications and action requests that had been initiated or revised as a
to take a specific action agreed to, or volunteered by, a licensee and submitted  
result of commitments made by the licensee to NRC.
in writing on the docket to the NRC.  
The program has a requirement that the licensee perform an annual review and assessment of
NRR guidelines  
site and corporate commitments. The most recent OCNGS annual review was reviewed by the
direct the NRR Project Manager to audit the licensee's  
 
commitment  
                                                - 3
management  
NRC staff. The annual review appeared thorough, addressing over 300 items. It identified
program by assessing  
isolated concerns with procedure annotation. Further, the NRC staff found that appropriate
the adequacy of the licensee's  
corrective actions were initiated.
implementation of a sample of commitments  
2.2     Verification of the Licensee's Program for Managing NRC Commitment Changes
made to the NRC in past licensing  
The primary focus of this part of the audit is to verify that the licensee has established
actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.). The  
administrative controls for modifying or deleting commitments made to the NRC. The NRC staff
audit is to be performed  
compared the licensee's process for controlling regulatory commitments to the guidelines in
every 3 years. 2.0 AUDIT PROCEDURE  
NEI-99-04, which the NRC has found to be an acceptable guide for licensees to follow for
AND RESULTS An audit of the Oyster Creek Nuclear Generating  
managing and changing commitments. The process used at OCNGS is contained in LS-AA
Station (OCNGS) commitment  
110 - Revision 6, "Commitment Management." The audit reviewed a sample of commitment
management  
changes that included changes that were or will be reported to the NRC, and changes that were
program was performed at the NRC Headquarters  
not or will not be reported to the NRC. The audit also verifies that the licensee's commitment
using documentation  
management system includes a mechanism to ensure traceability of commitments following
provided by the licensee and at the  
initial implementation. This ensures that licensee personnel are able to recognize that future
licensee's  
proposed changes to the affected design features or operating practices require evaluation in
Kennett Square office during the period of January and February 2009. The  
accordance with the commitment change control process.
audit reviewed commitments  
2.2.1     Audit Results
made since the  
Table 1 contains a list of those documents that were selected for additional review during this
previous audit in January 2004. The  
audit.
audit consisted of two major parts: (1)  
The NRC staff reviewed the licensee's procedure LS-AA-11 0, Revision 6,. Section 6.1 of the
verification of the licensee's  
procedure lists NEI 99-04 as a reference. The NRC staff found that LS-AA-11 0 generally
implementation of NRC commitments  
follows the guidance of NEI 99-04 and provides detailed instructions for making regulatory
that have been completed, and (2) verification of the licensee's  
commitments, tracking regulatory commitments, annotating documents to provide traceability of
program for managing changes to NRC commitments.  
commitments, and for making changes to commitments. Therefore, the NRC staff concludes
Enclosure
that the procedure used by the licensee to manage commitments provides the necessary
-2Verification
attributes for an acceptable commitment management program.
of Licensee's  
The NRC Staff noted that a self-assessment had been performed since the last NRC audit and
Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the  
the potential concern identified in the previous NRC audit about the use of multiple commitment
licensee has implemented  
tracking systems was addressed. Three recommendations from the self-assessment were
commitments made to the NRC as part of past licensing  
entered into the commitment tracking program and acted upon. One of the recommendations
actions/activities. For commitments not yet implemented, the NRC  
that OCNGS transition to the Passport tracking program (Exelon fleet-wide system) from the
staff determines  
use of multiple programs addressed the previous potential concern. Another recommendation
whether they have been captured in an  
addressed verification of proper annotation after the transfer. Related procedure
effective program for future  
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport,"
implementation. Audit Scope The audit addressed a sample of  
was also reviewed.
commitments made during the  
The NRC staff also reviewed documents that had been created or revised as a result of
review period. The audit focused on  
commitments made by the licensee to the NRC. The staff noted that, except as noted below,
regulatory  
the revised documents have annotations referring to commitments as part of the commitment
commitments (as defined  
change control process. These annotations serve to prevent the commitments from
above) made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.).  
inadvertently being deleted or altered without having gone through the commitment change
Commitments made in Licensee  
process. The NRC observed that in response to one commitment (Item 1 in Table 1)
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  
                                              - 4
compliance, not the specific methods used. Before the audit, the NRC  
emergency procedures were revised, an operations briefing developed and the training program
staff searched the  
augmented. It was further observed that one of the revised procedures, 2000-GLN-3200.01
Agencywide  
(Plant Specific Technical Guidelines for the Symptom Based Emergency Operating Procedures)
Documents Access and  
was annotated consistent with the procedural requirements. However, the "EOP Support
Management  
Procedure 7" referenced in the commitment (and referenced by 2000-GLN-3200.01) was not
System (ADAMS) for the licensee's  
annotated. As a result of discussions during this audit, an entry was made into the corrective
submittals since the last audit and selected a  
action program to evaluate the annotation requirements and determine if there are any
representative sample for verification. The audit excluded the  
extended implications.
following types of commitments that are internal to licensee processes: Commitments made on the  
3.0     CONCLUSION
licensee's own initiative  
As discussed above, the licensee's procedure used to implement and manage commitments
among internal organizational  
provides the necessary attributes for an acceptable commitment management program.
components. (Note: the internal  
4.0     LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
self-assessment  
Richard Gropp
and subsequent transition to the Exelon Passport program was audited as an  
Calvin Taylor
indicator of the commitment to the process.) Commitments that pertain to  
John Hufnagel
milestones of licensing  
Pam Cowan
actions/activities (e.g., respond to an NRC request for  
Principal Contributor: D. Egan
additional  
 
information by a certain date).  
                                                              - 5
Fulfillment of these commitments  
Item Source           Commitment                                                 Timeframe     Comments
was indicated by the fact that the  
    Source: 1/24/07 Oyster Creek [emergency operations procedure] EOP          Upon          Procedure
subject licensing  
  1  letter 2130-07  Support Procedure 7 will be revised to direct the           implementation EMG-SP7 - not annotated
action/activity  
    20448,          Operator to inject the entire contents of the Liquid Poison of approved
was completed. Commitments made as an internal reminder to take  
    Summary of      tank in the event that a [loss of coolant accident] LOCA is amendment.    (revised parent document
actions to comply with existing  
    Commitments.    in progress. Include these EOP changes and their basis                     annotated)
regulatory  
    Second item.    in Licensed Operator Training, and update the EOP
requirements such as regulations, technical  
    (ML07031 0101 0) User's Guide to include the use of sodium penta borate                    RCMT 189765-48
specifications, and updated final  
                      for pH control of the suppression pool under LOCA
safety analysis reports.  
                      conditions.
Fulfillment of these commitments was indicated by the licensee  
    Source: 7/3/08   First item on page 9: Oyster Creek will follow the         Upon          The commitments associated
having taken timely action in accordance  
  2  letter RA-08    guidelines in Section 11.3.6.5 of NUMARC 93-01, Rev. 3     implementation with License Amendment
with the subject requirements. Audit Results Table 1 contains a list of those  
    060, Attachment  during refueling within containment. Plant procedures       of approved    Request are being tracked
documents that were selected for  
    2. First item on will be revised, as appropriate, to implement these        amendment.    under Passport Action
additional  
    page 9 and last  guidelines.                                                               Requests 642132 and
review during this  
    item on page 10.                                                                            828005.
audit. The NRC staff found that the  
    (ML0819308020)  Last item on oaae 10: The following secondary               Note: This
licensee's  
                      containment potential openings will remain closed during   License        This issue is still under review
commitment  
                      refueling activities under administrative controls:         Amendment      by the NRC. The
tracking program had captured all the  
                          * Ventilation ductwork below siding structure on      Request has    commitments associated with
regulatory  
                              west side of Reactor Building (north end of west   not been      this License Amendment
commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant  
                              wall)                                             approved.      Request will be implemented
procedures, assessment  
                          * Ventilation ductwork below siding structure on                      as approved by the NRC.
recommendations, work orders, corrective  
                              west side of Reactor Building (south end of west
actions, training, qualification  
                              wall)
certifications and action requests that had been initiated or revised as a result of  
                          *   Trunion Room Doors to Turbine Building
commitments made by the licensee to NRC. The program has a  
                          * Reactor Building Commodities (flanged)
requirement that the licensee perform an annual  
                              penetration on north RB wall
review and assessment  
                          * MAC Facility Doors
of site and corporate  
                                                            Table 1
commitments. The most recent OCNGS annual  
 
review was reviewed by the
                                                              -6
-NRC staff. The annual review appeared thorough, addressing over 300 items. It identified isolated concerns with  
Item Source          Commitment                                                Timeframe      Comments
procedure annotation. Further, the NRC  
    Source; 2/2/07  The new pressure switch performance will be monitored      One year after IR 567038 - Actions initiated
staff found that appropriate corrective actions were initiated.  
  3  letter 2130-07 for a year to determine if periodic replacement of the    [license event by the corrective action
2.2 Verification of the Licensee's Program for Managing NRC  
    20450, Page 4. pressure switches is warranted.                           report] LER    program have resulted in
Commitment  
    Corrective                                                                submittal.    identifying adverse trends on
Changes The primary focus of this part of the audit is to verify that the licensee has  
    action planned                                                                            [electromagnetic relief valve]
established  
    item.                                                                                    EMRV instruments. Actions
administrative controls for  
    (ML0703803170)                                                                            initiated by the [corrective
modifying or deleting  
                                                                                              actions] have resulted in
commitments made to the NRC. The NRC staff compared the  
                                                                                              implementing replacement of
licensee's  
                                                                                              the pressure switches and
process for controlling  
                                                                                              control relays and
regulatory  
                                                                                              establishing routine
commitments to the guidelines  
                                                                                              replacement [preventative
in NEI-99-04, which the NRC has found to be an  
                                                                                              maintenance] tasks.
acceptable guide for  
    Source: 3/28/05 To ensure that the Standby Liquid Control system is       Within 90 days Procedures
licensees to follow for managing and changing  
  4  letter 2130-05 initiated in the event of a [large break] LOCA, the Oyster of NRC        EMG-SP7, 2000-GLN
commitments. The process used at  
    20040, Page 1  Creek [EOPs] will be revised as required.                  issuance of    3200.01
OCNGS is contained in 110 -Revision 6, "Commitment  
    of attachment.                                                            license
Management." The audit reviewed a sample of  
    Item listed                                                                amendment.    (refer also to Item 1)
commitment changes that included  
    (ML0509042340)
changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The audit also verifies that the  
                                                                                              RCMT 189765-48
licensee's  
                                                            Table 1
commitment  
 
management  
                                                            -7
system includes a mechanism to ensure  
Item Source          Commitment                                                Timeframe    Comments
traceability  
    Source: 3/31/05 Revise the administrative procedure for control of EOP    CAP 02004  AD-OC-103, "EOP/SAM
of commitments  
  5  letter 2130-05 documents (CC-AA-309, Control of Design Analysis) to      1986-12 was  [severe accident mitigation]
following  
    20062,         include instructions to use the appropriate configuration completed on Program Control," includes
initial implementation.  
    Attachment 2.   control process to revise the plant specific technical    12/02/2004  annotations associated with
This ensures that licensee personnel are able to recognize that future proposed changes to the  
    Second item.    guidelines (PSTG) Appendix C criteria.                                the implementation of this
affected design features or operating  
    (ML0509600680)                                                                        commitment.
practices require evaluation in  
                                                                                              * Section 6.5.2 - CM-2,
accordance with the commitment change control process.  
                                                                                                LAR 05012.02, Nov EA
2.2.1 Audit Results Table 1 contains a list of those  
                                                                                                04-213 (Steps 4.1.3.13,
documents that were selected for  
                                                                                                4.1.3.14).
additional review during this  
                                                                                              * Section 4.1.3.13 - Any
audit. The NRC staff reviewed the  
                                                                                                change to a design
licensee's procedure LS-AA-110, Revision 6,. Section 6.1 of the procedure lists NEI 99-04 as a reference. The NRC  
                                                                                                input, setpoint, used in
staff found that LS-AA-11 0  
                                                                                                Appendix C to the
generally follows the  
                                                                                                PSTGs shall be
guidance of NEI 99-04 and provides detailed  
                                                                                                controlled in accordance
instructions for making regulatory commitments, tracking  
                                                                                                with CC-AA-102,
regulatory  
                                                                                                "Design Input and
commitments, annotating  
                                                                                                Configuration Change
documents to provide  
                                                                                                  Impact Screening. (CM
traceability  
                                                                                                2)
of commitments, and for making  
                                                                                              * Section 4.1.3.14 - All
changes to commitments.  
                                                                                                changes to the
Therefore, the NRC staff concludes that the procedure used by the  
                                                                                                calculations in Appendix
licensee to manage  
                                                                                                C to the PSTGs shall be
commitments provides the  
                                                                                                controlled in accordance
necessary attributes for an  
                                                                                                with Procedure CC-AA
acceptable  
                                                                                                309, "Control of Design
commitment  
                                                                                                Analyses." (CM-2)
management  
                                                                                            RCMT
program. The NRC Staff noted that a  
                                                                                            620989-05
self-assessment had been performed since the last NRC audit and the potential concern identified in the previous NRC audit about the use of multiple  
                                                          Table 1
commitment  
 
tracking systems was addressed.  
                                                            -8
Three recommendations from the self-assessment  
Item Source          Commitment                                              Timeframe    Comments
were entered into the  
    Source:        Page 7                                                  Actions      IR
commitment tracking program and acted upon. One of the  
  6 Attachment 3 of                                                          Completed    487012-10
recommendations that OCNGS  
    Self-           *  Verification of proper annotation of current                      (references
transition to the Passport tracking program (Exelon  
    Assessment.       commitments using PassPort after data transfer.                   IR 528865-48)
fleet-wide  
    Page 7, second    (487012-10)
system) from the use of multiple  
    and third DC                                                                          IR
programs addressed the previous potential concern.  
    items and Page  *  Transfer of data to PassPort and train site on proper              380386 -01,02,03,04, and
Another recommendation  
    10 - DC items.     commitment management. (487012-10)                                05
addressed  
                    Page 10                                                              Internal actions completed as
verification  
                                                                                          a result of self-assessment
of proper annotation after the transfer. Related  
                    * Lotus Notes Database currently not site-wide
procedure  
                        searchable and known commitments may be missed.
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport," was also reviewed. The NRC staff also reviewed  
                        (IR 380386)
documents that had been created or revised as a result of  
    Commitment      *  Commitment Tracking Numbers 08-006, 08-004          Procedural  Attachment 1 from LS-AA
commitments made by the  
  7 Change            R1,08-002                                            requirements 110
licensee to the NRC. The  
    Evaluation                                                              completed
staff noted that, except as noted below, the revised  
    Forms.                                                                               Commitment changes
documents  
                                                                                          requiring both the need to
have annotations referring to  
                                                                                          inform and not inform NRC
commitments as part of the  
                                                          Table 1
commitment change control process.  
 
These annotations serve to prevent the  
Mr. Charles G. Pardee
commitments  
President and Chief Nuclear Officer
from inadvertently being deleted or altered without having gone through the  
Exelon Generation Company
commitment  
4300 Winfield Road
change process. The NRC observed that in response to one  
Warrenville, IL 60555
commitment (Item 1 in Table 1)
SUB~IECT        OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF
-emergency  
                EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.
procedures were revised, an operations briefing  
                ME0362)
developed and the training program augmented. It was  
Dear Mr. Pardee:
further observed that one of the revised  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power
procedures, 2000-GLN-3200.01 (Plant Specific  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory
Technical  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,
Guidelines for the Symptom Based  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for
Emergency Operating Procedures) was annotated  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or
consistent with the procedural requirements. However, the "EOP Support  
similar administrative controls to ensure that regulatory commitments are implemented and that
Procedure  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the
7" referenced in the  
NRC.
commitment (and referenced by  
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of
2000-GLN-3200.01) was not annotated. As a result of  
licensees' commitment management programs once every 3 years to determine whether the
discussions during this audit, an entry was made into the corrective action program to evaluate the annotation  
licensees' programs are consistent with the industry gUidance in NEI 99-04, and that regulatory
requirements  
commitments are being effectively implemented.
and determine if there are any extended implications.  
An audit of OCNGS's commitment management program was performed during January and
3.0 CONCLUSION As discussed above, the  
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,
licensee's procedure used to  
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
implement and manage commitments provides the  
acceptable program for implementing and managing NRC commitments. Details of the audit
necessary  
are set forth in the enclosed audit report.
attributes for an acceptable  
                                              Sincerely,
commitment  
                                              G. Edward Miller, Project Manager
management  
                                              Plant Licensing Branch 1-2
program. 4.0 LICENSEE PERSONNEL  
                                              Division of Operating Reactor Licensing
CONTACTED FOR THIS AUDIT Richard Gropp  
                                              Office of Nuclear Reactor Regulation
Calvin Taylor John Hufnagel Pam Cowan Principal Contributor: D. Egan
Docket No. 50-219
-Item Source Commitment  
Enclosure: Audit Report
Timeframe  
cc w/encl: Distribution via ListServ
Comments 1 Source: 1/24/07 letter 20448, Summary of Commitments. Second item. (ML07031 01010) Oyster Creek [emergency  
DISTRIBUTION:
operations  
Public                                        LPL1-2 Reading Resource
procedure]  
RidsAcrsAcnw_MailCTR Resource                  RidsNrrDorlLpl1-2 Resource
EOP Support Procedure 7 will be revised to direct the  
RidsNrrPMEMiller Resource                      RidsNrrLAABaxter Resource
Operator to inject the entire  
RidsOgc Resource                              RidsRgn1 MailCenter Resource
contents of the Liquid Poison tank in the event that a [loss  
RidsNrrDorlDpr Resource
of coolant accident]  
ACCESSION No'.. ML090570036                    NRR-106        * via email
LOCA is in progress. Include these EOP  
    OFFICE          LPLI-2\PM          LPLI-2\PM            LPLI-2\LA            LPLI-2\BC
changes and their basis in Licensed  
    NAME              GMiller            DEgan                ABaxter            HChernoff
Operator Training, and update the EOP User's Guide to include the use of sodium pentaborate for pH control of the  
    DATE            2/27109            02/26/09            02/27/09*             2/27109
suppression  
                                    OFFICIAL RECORD COPY
pool under LOCA conditions.  
Upon implementation
of approved amendment.
Procedure
EMG-SP7 -not annotated (revised parent document annotated)
RCMT 189765-48
2 Source: 7/3/08 letter 060, Attachment 2. First item on page 9 and last
item on page 10. (ML0819308020) First item on page 9:
Oyster Creek will  
follow the guidelines in Section  
11.3.6.5 of NUMARC 93-01, Rev. 3 during refueling within  
containment.  
Plant procedures will be revised, as  
appropriate, to implement  
these guidelines. Last item on oaae 10: The  
following  
secondary  
containment  
potential  
openings will remain closed during refueling activities  
under administrative  
controls:  
* Ventilation  
ductwork below siding  
structure  
on west side of  
Reactor Building (north end of west  
wall) * Ventilation
ductwork below siding  
structure  
on west side  
of Reactor Building (south end of west  
wall) * Trunion Room Doors to  
Turbine Building * Reactor Building  
Commodities (flanged) penetration on north RB wall  
* MAC Facility Doors  
Upon implementation
of approved amendment. Note: This
License Amendment
Request has not been approved.
The commitments
associated with License
Amendment
Request are being tracked
under Passport Action Requests 642132 and 828005. This issue is still
under review by the NRC. The
commitments
associated
with this License
Amendment
Request will be implemented
as approved by the NRC.
Table 1 
-6 Item Source Commitment
Timeframe
Comments 3 Source; 2/2/07 letter 20450, Page 4.
Corrective action planned
item. (ML0703803170) The new pressure switch
performance will be monitored for a year to
determine
if periodic replacement of the pressure switches is  
warranted. One year after
[license event report] LER
submittal.  
IR 567038 -Actions initiated by the corrective
action program have resulted in
identifying
adverse trends on
[electromagnetic relief valve]
EMRV instruments.
Actions initiated by the [corrective
actions] have resulted in
implementing
replacement
of the pressure switches and control relays and
establishing
routine replacement
[preventative
maintenance]  
tasks. 4 Source: 3/28/05 letter 20040, Page 1
of attachment. Item listed (ML0509042340) To ensure that the  
Standby Liquid Control system is initiated in the event of a [large break] LOCA, the
Oyster Creek [EOPs] will be revised as required. Within 90 days of NRC issuance of license amendment.  
Procedures
EMG-SP7, 3200.01 (refer also to Item 1)
RCMT 189765-48
Table 1
-7 Item Source Commitment
Timeframe
Comments 5 Source: 3/31/05 letter 20062, Attachment
2. Second item. (ML0509600680) Revise the  
administrative
procedure for control
of EOP documents (CC-AA-309, Control of Design  
Analysis)  
to include instructions to use the  
appropriate
configuration control process to revise the plant
specific technical
guidelines (PSTG) Appendix C criteria.
CAP 1986-12 was
completed
on 12/02/2004
AD-OC-103, "EOP/SAM [severe accident mitigation] Program Control," includes
annotations associated with
the implementation of this commitment.
* Section 6.5.2 -CM-2, LAR 05012.02, Nov
04-213 (Steps 4.1.3.13, 4.1.3.14).
* Section 4.1.3.13 -Any change to a design input, setpoint, used in
Appendix C to the PSTGs shall be
controlled
in accordance with CC-AA-102, "Design Input and  
Configuration
Change Impact Screening.  
2) * Section 4.1.3.14 -All changes to the calculations
in Appendix C to the PSTGs shall be
controlled
in accordance with Procedure 309, "Control of Design
Analyses." (CM-2) RCMT 620989-05
Table 1  
-8 Item Source Commitment
Timeframe
Comments 6 Source: Attachment 3 of Self-Assessment. Page 7, second and third
DC items and Page 10 -DC items. Page 7 * Verification of
proper annotation of
current commitments using
PassPort after data transfer.  
(487012-10)
* Transfer of data to  
PassPort and train site on
proper commitment
management.  
(487012-10) Page 10 * Lotus Notes
Database currently not site-wide searchable and known
commitments may be missed. (IR 380386)
Actions Completed
IR 487012-10 (references
IR 528865-48)  
IR 380386 -01,02,03,04, and 05 Internal actions completed as a result of
self-assessment
7 Commitment
Change Evaluation
Forms. * Commitment  
Tracking Numbers 08-006, R1,08-002
Procedural
requirements
completed
Attachment 1 from 110 Commitment
changes requiring both the need to inform and not inform NRC  
Table 1 
Mr. Charles G. Pardee President and
Chief Nuclear Officer Exelon Generation
Company 4300 Winfield Road Warrenville, IL 60555 OYSTER CREEK NUCLEAR GENERATING
STATION (OCNGS) -AUDIT OF EXELON'S MANAGEMENT
OF REGULATORY
COMMITMENTS (TAC NO. ME0362) Dear Mr. Pardee: In Regulatory Issue
Summary 2000-17, "Managing
Regulatory
Commitments Made by Power
Reactor Licensees to the NRC Staff," dated
September
21,2000, the U. S.
Nuclear Regulatory
Commission (NRC) informed
licensees that the Nuclear Energy Institute
document NEI 99-04, "Guidelines
for Managing NRC Commitment
Changes," contains acceptable
guidance for controlling regulatory
commitments
and 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
OCNGS's commitment
management program was
performed during January and February 2009, including
activities at Exelon's office in Kennett Square, PA on February 24, 2009. The NRC
staff concludes, based on the audit, that OCNGS has
implemented
an acceptable program for
implementing and managing NRC
commitments. Details of the audit are set forth in the
enclosed audit report.
Sincerely, G. Edward Miller, Project
Manager Plant Licensing Branch
1-2 Division of Operating
Reactor Licensing Office of
Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Audit Report cc w/encl: Distribution
via ListServ DISTRIBUTION:
Public LPL1-2 Reading
Resource RidsAcrsAcnw_MailCTR
Resource RidsNrrDorlLpl1-2
Resource RidsNrrPMEMiller
Resource RidsNrrLAABaxter
Resource RidsOgc Resource
RidsRgn1 MailCenter
Resource RidsNrrDorlDpr
Resource ACCESSION
No'.. ML090570036 NRR-106 * via email
OFFICE LPLI-2\PM
LPLI-2\PM
LPLI-2\LA
LPLI-2\BC
NAME GMiller DEgan ABaxter HChernoff
DATE 2/27109 02/26/09 02/27/09*
2/27109 OFFICIAL RECORD
}}
}}

Revision as of 08:40, 14 November 2019

(OCNGS) - Audit of the Exelon'S Management of Regulatory Commitments
ML090570036
Person / Time
Site: Oyster Creek
Issue date: 02/27/2009
From: Geoffrey Miller
Plant Licensing Branch 1
To: Pardee C
Exelon Generation Co
Miller, G. Edward, 415-2481
References
RIS-00-017, TAC ME0362
Download: ML090570036 (10)
v • d • e


See also: RIS 2000-17

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

February 27, 2009

Mr. Charles G. Pardee

President and Chief Nuclear Officer

Exelon Generation Company

4300 Winfield Road

Warrenville, IL 60555

SUB..IECT OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF

EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.

ME0362)

Dear Mr. Pardee:

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power

Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory

Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,

"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for

controlling regulatory commitments and 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 Requtation 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 OCNGS's commitment management program was performed during January and

February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,

2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an

acceptable program for implementing and managing NRC commitments. Details of the audit

are set forth in the enclosed audit report.

G. dward Miller, Project Man ger

Plant Licensing Branch 1-2

Division of Operating Reactor Licensing

Office of Nuclear Reactor Regulation

Docket No. 50-219

Enclosure: Audit Report

cc w/encl: Distribution via ListServ

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION

LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS

OYSTER CREEK NUCLEAR GENERATING STATION

DOCKET NO. 50-219

1.0 INTRODUCTION AND BACKGROUND

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power

Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory

Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,

"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for

controlling regulatory commitments and 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 (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.

NEI-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action

agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

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.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS

An audit of the Oyster Creek Nuclear Generating Station (OCNGS) commitment management

program was performed at the NRC Headquarters using documentation provided by the

licensee and at the licensee's Kennett Square office during the period of January and February

2009. The audit reviewed commitments made since the previous audit in January 2004. The

audit consisted of two major parts: (1) verification of the licensee's implementation of NRC

commitments that have been completed, and (2) verification of the licensee's program for

managing changes to NRC commitments.

Enclosure

-2

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.

2.1.1 Audit Scope

The audit addressed a sample of commitments made during the review period. The audit

focused on regulatory commitments (as defined above) made in writing to the NRC as a result

of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins,

generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices

of Violation may be included in the sample, but the review will be limited to verification of

restoration of compliance, not the specific methods used. Before the audit, the NRC staff

searched the Agencywide Documents Access and Management System (ADAMS) for the

licensee's submittals since the last audit and selected a representative sample for verification.

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

(1) Commitments made on the licensee's own initiative among internal organizational

components. (Note: the internal self-assessment and subsequent transition to the

Exelon Passport program was audited as an indicator of the commitment to the

process.)

(2) Commitments that pertain to milestones of licensing actions/activities (e.g., respond to

an NRC request for additional information by a certain date). Fulfillment of these

commitments was indicated by the fact that the subject licensing action/activity was

completed.

(3) Commitments made as an internal reminder to take actions to comply with existing

regulatory requirements such as regulations, technical specifications, and updated final

safety analysis reports. 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 contains a list of those documents that were selected for additional review during this

audit.

The NRC staff found that the licensee's commitment tracking program had captured all the

regulatory commitments that were identified by the NRC staff before the audit. The NRC staff

also reviewed plant procedures, assessment recommendations, work orders, corrective actions,

training, qualification certifications and action requests that had been initiated or revised as a

result of commitments made by the licensee to NRC.

The program has a requirement that the licensee perform an annual review and assessment of

site and corporate commitments. The most recent OCNGS annual review was reviewed by the

- 3

NRC staff. The annual review appeared thorough, addressing over 300 items. It identified

isolated concerns with procedure annotation. Further, the NRC staff found that appropriate

corrective actions were initiated.

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 OCNGS is contained in LS-AA

110 - Revision 6, "Commitment Management." The audit reviewed a sample of commitment

changes that included changes that were or will be reported to the NRC, and changes that were

not or will not be reported to the NRC. 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.

2.2.1 Audit Results

Table 1 contains a list of those documents that were selected for additional review during this

audit.

The NRC staff reviewed the licensee's procedure LS-AA-11 0, Revision 6,. Section 6.1 of the

procedure lists NEI 99-04 as a reference. The NRC staff found that LS-AA-11 0 generally

follows the guidance of NEI 99-04 and provides detailed instructions for making regulatory

commitments, tracking regulatory commitments, annotating documents to provide traceability of

commitments, and for making changes to commitments. Therefore, the NRC staff concludes

that the procedure used by the licensee to manage commitments provides the necessary

attributes for an acceptable commitment management program.

The NRC Staff noted that a self-assessment had been performed since the last NRC audit and

the potential concern identified in the previous NRC audit about the use of multiple commitment

tracking systems was addressed. Three recommendations from the self-assessment were

entered into the commitment tracking program and acted upon. One of the recommendations

that OCNGS transition to the Passport tracking program (Exelon fleet-wide system) from the

use of multiple programs addressed the previous potential concern. Another recommendation

addressed verification of proper annotation after the transfer. Related procedure

LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport,"

was also reviewed.

The NRC staff also reviewed documents that had been created or revised as a result of

commitments made by the licensee to the NRC. The staff noted that, except as noted below,

the revised documents have annotations referring to commitments as part of the commitment

change control process. These annotations serve to prevent the commitments from

inadvertently being deleted or altered without having gone through the commitment change

process. The NRC observed that in response to one commitment (Item 1 in Table 1)

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emergency procedures were revised, an operations briefing developed and the training program

augmented. It was further observed that one of the revised procedures, 2000-GLN-3200.01

(Plant Specific Technical Guidelines for the Symptom Based Emergency Operating Procedures)

was annotated consistent with the procedural requirements. However, the "EOP Support

Procedure 7" referenced in the commitment (and referenced by 2000-GLN-3200.01) was not

annotated. As a result of discussions during this audit, an entry was made into the corrective

action program to evaluate the annotation requirements and determine if there are any

extended implications.

3.0 CONCLUSION

As discussed above, the licensee's procedure used to implement and manage commitments

provides the necessary attributes for an acceptable commitment management program.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT

Richard Gropp

Calvin Taylor

John Hufnagel

Pam Cowan

Principal Contributor: D. Egan

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Item Source Commitment Timeframe Comments

Source: 1/24/07 Oyster Creek [emergency operations procedure] EOP Upon Procedure

1 letter 2130-07 Support Procedure 7 will be revised to direct the implementation EMG-SP7 - not annotated

20448, Operator to inject the entire contents of the Liquid Poison of approved

Summary of tank in the event that a [loss of coolant accident] LOCA is amendment. (revised parent document

Commitments. in progress. Include these EOP changes and their basis annotated)

Second item. in Licensed Operator Training, and update the EOP

(ML07031 0101 0) User's Guide to include the use of sodium penta borate RCMT 189765-48

for pH control of the suppression pool under LOCA

conditions.

Source: 7/3/08 First item on page 9: Oyster Creek will follow the Upon The commitments associated

2 letter RA-08 guidelines in Section 11.3.6.5 of NUMARC 93-01, Rev. 3 implementation with License Amendment

060, Attachment during refueling within containment. Plant procedures of approved Request are being tracked

2. First item on will be revised, as appropriate, to implement these amendment. under Passport Action

page 9 and last guidelines. Requests 642132 and

item on page 10. 828005.

(ML0819308020) Last item on oaae 10: The following secondary Note: This

containment potential openings will remain closed during License This issue is still under review

refueling activities under administrative controls: Amendment by the NRC. The

  • Ventilation ductwork below siding structure on Request has commitments associated with

west side of Reactor Building (north end of west not been this License Amendment

wall) approved. Request will be implemented

  • Ventilation ductwork below siding structure on as approved by the NRC.

west side of Reactor Building (south end of west

wall)

  • Trunion Room Doors to Turbine Building
  • Reactor Building Commodities (flanged)

penetration on north RB wall

  • MAC Facility Doors

Table 1

-6

Item Source Commitment Timeframe Comments

Source; 2/2/07 The new pressure switch performance will be monitored One year after IR 567038 - Actions initiated

3 letter 2130-07 for a year to determine if periodic replacement of the [license event by the corrective action

20450, Page 4. pressure switches is warranted. report] LER program have resulted in

Corrective submittal. identifying adverse trends on

action planned [electromagnetic relief valve]

item. EMRV instruments. Actions

(ML0703803170) initiated by the [corrective

actions] have resulted in

implementing replacement of

the pressure switches and

control relays and

establishing routine

replacement [preventative

maintenance] tasks.

Source: 3/28/05 To ensure that the Standby Liquid Control system is Within 90 days Procedures

4 letter 2130-05 initiated in the event of a [large break] LOCA, the Oyster of NRC EMG-SP7, 2000-GLN

20040, Page 1 Creek [EOPs] will be revised as required. issuance of 3200.01

of attachment. license

Item listed amendment. (refer also to Item 1)

(ML0509042340)

RCMT 189765-48

Table 1

-7

Item Source Commitment Timeframe Comments

Source: 3/31/05 Revise the administrative procedure for control of EOP CAP 02004 AD-OC-103, "EOP/SAM

5 letter 2130-05 documents (CC-AA-309, Control of Design Analysis) to 1986-12 was [severe accident mitigation]

20062, include instructions to use the appropriate configuration completed on Program Control," includes

Attachment 2. control process to revise the plant specific technical 12/02/2004 annotations associated with

Second item. guidelines (PSTG) Appendix C criteria. the implementation of this

(ML0509600680) commitment.

  • Section 6.5.2 - CM-2,

LAR 05012.02, Nov EA

04-213 (Steps 4.1.3.13,

4.1.3.14).

  • Section 4.1.3.13 - Any

change to a design

input, setpoint, used in

Appendix C to the

PSTGs shall be

controlled in accordance

with CC-AA-102,

"Design Input and

Configuration Change

Impact Screening. (CM

2)

  • Section 4.1.3.14 - All

changes to the

calculations in Appendix

C to the PSTGs shall be

controlled in accordance

with Procedure CC-AA

309, "Control of Design

Analyses." (CM-2)

RCMT

620989-05

Table 1

-8

Item Source Commitment Timeframe Comments

Source: Page 7 Actions IR

6 Attachment 3 of Completed 487012-10

Self- * Verification of proper annotation of current (references

Assessment. commitments using PassPort after data transfer. IR 528865-48)

Page 7, second (487012-10)

and third DC IR

items and Page * Transfer of data to PassPort and train site on proper 380386 -01,02,03,04, and

10 - DC items. commitment management. (487012-10) 05

Page 10 Internal actions completed as

a result of self-assessment

  • Lotus Notes Database currently not site-wide

searchable and known commitments may be missed.

(IR 380386)

Commitment * Commitment Tracking Numbers08-006, 08-004 Procedural Attachment 1 from LS-AA

7 Change R1,08-002 requirements 110

Evaluation completed

Forms. Commitment changes

requiring both the need to

inform and not inform NRC

Table 1

Mr. Charles G. Pardee

President and Chief Nuclear Officer

Exelon Generation Company

4300 Winfield Road

Warrenville, IL 60555

SUB~IECT OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF

EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.

ME0362)

Dear Mr. Pardee:

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power

Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory

Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,

"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for

controlling regulatory commitments and 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 OCNGS's commitment management program was performed during January and

February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,

2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an

acceptable program for implementing and managing NRC commitments. Details of the audit

are set forth in the enclosed audit report.

Sincerely,

G. Edward Miller, Project Manager

Plant Licensing Branch 1-2

Division of Operating Reactor Licensing

Office of Nuclear Reactor Regulation

Docket No. 50-219

Enclosure: Audit Report

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