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, 2007 Mr. James A. Spina, Vice President Calvert 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 - AUDIT OF THE LICENSEES 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 Nuclear Power 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 the resources 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 Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

As stated cc w/encl: See next page

September 18, 2007 Mr. James A. Spina, Vice President Calvert 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 - AUDIT OF THE LICENSEES 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 Nuclear Power 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 the resources 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 Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

As stated cc w/encl: See next page Distribution PUBLIC LPL1-1 RidsNrrDorlLpl1-1 RidsNrrPMDPickett RidsNrrLASLittle RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn1MailCenter Accession: ML072480261 OFFICE LPLI-1 LPLl-1/PM LPLI-1/LA LPLI-1/BC NAME DWoodyatt DPickett SLittle MKowal DATE 09 /13/ 07 09 /13/ 07 09 /12/ 07 09 /18/ 07 OFFICIAL RECORD COPY

Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:

Mr. Michael J. Wallace, President Regional Administrator, Region I Constellation Generation Group U.S. Nuclear Regulatory Commission 750 East Pratt Street 475 Allendale Road Baltimore, MD 21202 King of Prussia, PA 19406 Mr. John M. Heffley Ms. Kristen A. Burger, Esquire Senior Vice President and Maryland People's Counsel Chief Nuclear Officer 6 St. Paul Centre Constellation Generation Group Suite 2102 1997 Annapolis Exchange Parkway Baltimore, MD 21202-1631 Suite 310 Annapolis, MD 21401 Ms. Patricia T. Birnie, Esquire Co-Director President Maryland Safe Energy Coalition Calvert County Board of P.O. Box 33111 Commissioners Baltimore, MD 21218 175 Main Street Prince Frederick, MD 20678 Mr. Roy Hickok NRC Technical Training Center Mr. Carey Fleming, Esquire 5700 Brainerd Road Sr. Counsel - Nuclear Generation Chattanooga, TN 37411-4017 Constellation Generation Group, LLC 750 East Pratt Street, 17th floor Baltimore, MD 21202 Mr. Jay S. Gaines Director, Licensing Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. R. I. McLean, Manager Nuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)

Tawes State Office Building Annapolis, MD 21401

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)

REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)

CALVERT CLIFFS NUCLEAR POWER PLANT, INC.

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318

1.0 INTRODUCTION

In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing 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 handling regulatory 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 licensees commitment management program by assessing the adequacy of the licensees 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 Since no audit was performed before the issuance of NEI 99-04, the NRC staff defined the period 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.

2.1 Verification of Licensees Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented those commitments 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 Enclosure

satisfied both the action committed to and the overall intent of the commitment. The licensee views a commitment as any action they agree to perform. The staffs findings are summarized in the attached table.

2.2 Verification of Licensees Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensees performance related to implementing controls for modifying or deleting commitments made to the NRC. The staff examined the licensees commitment tracking system and the NRC commitment management procedures.

When the licensee incorporates commitments into plant procedures, the licensee includes a reference code to the document originating the commitment. If the licensee changes or deletes a commitment, the licensees 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 the annual revision of the Updated Final Safety Analysis Report. This attachment describes the original 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 licensees programs and procedures.

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

3.0 CONCLUSION

Based on the above, the NRC staff concludes that; (1) the licensee had implemented or is tracking 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 AUDIT Betty Dough Patricia Furio Craig Neyman Principal Contributor: Diana Woodyatt, NRR Date: September 18, 2007

Attachment:

As stated

AUDIT OF CONSTELLATION ENERGY MANAGEMENT OF REGULATORY COMMITMENTS AT CALVERT CLIFFS NUCLEAR POWER PLANT PERFORMED AUGUST 14, 2007 LIST OF COMMITMENTS INCLUDED IN AUDIT Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 1 CT200400031 09/21/2004 In order to verify that interim compensatory Closed Nuclear Security reviewed the measures (ICM) for independent spent fuel ISFSI ICMs and determined storage installations (ISFSI) remain that the activities found in the unchanged, the licensee must respond to Security Plan and Contingency the NRC in writing within 10 days of receipt Plan for the ISFSI did not of 09/10/2004 letter from NRC;

Subject:

decrease the effectiveness of Implementation Status of Independent the ISFSI ICMs. A letter dated Spent Fuel Storage Installation Interim 09/27/2004 was sent to the Compensatory Measures (TAC Nos. NRC stating the effectiveness MC2900 and MC2901) of the ISFSI ICMs.

2 CT200400033 09/28/2004 Amendment Nos. 269 and 245 remove Closed Two groups within the Calvert Technical Specification (TS) 5.5.3, Post- Cliffs organization reviewed the Accident Sampling System, from Calvert safety evaluation and Cliffs Nuclear Power Plant Unit Nos. 1 and determined that the TS were 2, respectively. Commitment is to review correct.

safety evaluation report deleting TS 5.5.3 and check the TS for accuracy.

Attachment

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 3 CT200400041 12/17/2004 Determine participants for January 14, 2005 Closed The names, titles, NRC workshop on enhancing reactor organizations, and details of mitigative measure and strategies. Email, to participants were sent to the the NRC, the name, title and organization NRC.

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.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 4 CT200500008 02/22/2005 Relief request - Weld overlay and alternative Closed Parts 1, 3, 4, and 5 were techniques, Third Ten-Year Inservice discontinued from commitment.

Inspection Interval. (1) Demonstrate Part 2 was completed by production weld within heat sink chemical analysis by x-ray temperature limits by testing on a fluorescence performed on conservative mockup. (2) Regularly monitor overlay layers on mockups; an production welds with contact pyrometers analysis was performed above and/or temperature indicating crayons, ferritic, Alloy 82/182, and record. (3) Use mockups to identify first austenitic stainless steel base weld layer where a 24% minimum Cr metals; the second layer content is achieved over the base materials. contained a Cr content greater (4) Production structural overlay performed than 24% and therefore with same welding parameters as mockups. credited toward design (5) Ultrasonic inspection of weld overlay. thickness. Part 6 was closed (6) Monitor process temperatures, provide by documenting the manual record, calibrate pyrometers in temperatures taken during accordance with Measuring and Test installation of the weld overlays Equipment (M&TE) program. (7) Apply and attaching a copy of the 360° full structural weld overlay to control M&TE calibration data. Part 7 crack growth, maintain weld integrity. was closed by documenting the installation of a 360° weld overlay on the hot leg drain nozzle and the cold leg letdown nozzle.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 5 CT200500013 03/13/2005 Request for Approval of a Common Quality Closed The request for approval of a Assurance (QA) Program for Constellation common QA Program was Generation Group, LLC. - Review the withdrawn 08/24/2005 in a Calvert Cliffs QA Policy and the QA Topical letter from the licensee.

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.

6 CT200500020 05/20/2005 Review Draft Regulatory Guide DG-8029, Closed Calvert Cliffs Health Physics proposed Revision 2 to Regulatory Guide department reviewed the draft 8.7, Instructions for Recording and guide and concluded that the Reporting Occupational Radiation Dose draft has no new requirements Data and provided comments to the NRC and was created for the via http://www.nrc.gov/what-we- purpose of providing greater do/regulatory/rulemaking.html. clarification to the user when recording and reporting radiation dose data and there are no comments for the NRC.

7 CT200500028 08/23/2005 Provide input and respond to NRC Request Closed On 09/16/2005 Calvert Cliffs for Additional Information regarding submitted a letter to the NRC requirements related to positive reactivity with their response to the additions from NRC letter dated 08/19/2005. request for additional information.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 8 CT200500032 10/04/2005 Underwater welding of heated junction Closed Welder qualification completed thermocouple (HJTC) probe holders. through mockup testing and Perform mockup testing for welders using inspections performed as similar materials and under similar specified. A work order was conditions as the production welds. Perform developed to perform HJTC inspection of sample welds to the same probe holders to the UGS plate requirements as the production welds. in compliance with the Verify that the weld procedure specification requirements of ASME Section approved for use in welding HJTC probe IX and Code Case N-516-G-3, holders to the upper guide structure (UGS) Revision 2.

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.

9 CT200500038 11/07/2005 Review NRC Regulatory Issue Summary Closed The RIS was reviewed for (RIS) 2005-25, Clarification of NRC applicability to the Calvert Cliffs Guidelines for Control of Heavy Loads, for Reactor Vessel Head applicability and program changes. 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.