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| number = ML060940527
| number = ML060940527
| issue date = 04/18/2006
| issue date = 04/18/2006
| title = Three Mile Island Unit 1 Nuclear Station - Audit of the Licensee'S Management of Regulatory Commitments (TAC No. MC8310)
| title = Nuclear Station - Audit of the Licensee'S Management of Regulatory Commitments
| author name = Saba F E
| author name = Saba F
| author affiliation = NRC/NRR/ADRO/DORL
| author affiliation = NRC/NRR/ADRO/DORL
| addressee name = Crane C M
| addressee name = Crane C
| addressee affiliation = AmerGen Energy Co, LLC
| addressee affiliation = AmerGen Energy Co, LLC
| docket = 05000289
| docket = 05000289
Line 14: Line 14:
| page count = 18
| page count = 18
| project = TAC:MC8310
| project = TAC:MC8310
| stage = Other
| stage = Acceptance Review
}}
}}


=Text=
=Text=
{{#Wiki_filter:April 18, 2006Mr. Christopher M. CranePresident and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
{{#Wiki_filter:April 18, 2006 Mr. Christopher M. Crane President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555


==SUBJECT:==
==SUBJECT:==
THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - AUDIT OF THELICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC8310)
THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC8310)


==Dear Mr. Crane:==
==Dear Mr. Crane:==


The Nuclear Regulatory Commission (NRC) staff is required to audit a licensee's commitmentmanagement program once every 3 years, in accordance with the NRC Office of NuclearReactor Regulation Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC."  LIC-105, which is publicly available electronically from the AgencywideDocuments Access and Management Systems Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML042320463), provides the NRC staff and itsstakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI) in NEI 99-04, "Guidance for Managing NRC Commitment Changes." An audit of AmerGen Energy Company, LLC's (AmerGen's) commitment management programfor the Three Mile Island Nuclear Station, Unit No. 1 was performed at AmerGen's office in Kennett Square, Pennsylvania, on January 11 and 12, 2006. Based on this audit, the NRC staffconcludes that: (1) the licensee had implemented NRC commitments on a timely basis; and (2)the licensee had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
The Nuclear Regulatory Commission (NRC) staff is required to audit a licensees commitment management program once every 3 years, in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management Systems Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML042320463), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes.
C. Crane-2-The NRC staff appreciates the resources that were available by your staff, both before and during the audit. If you have any questions, please have your staff contact me at (301) 415-1447.Sincerely,/RA/Farideh E. Saba, Project ManagerPlant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-289
An audit of AmerGen Energy Company, LLCs (AmerGens) commitment management program for the Three Mile Island Nuclear Station, Unit No. 1 was performed at AmerGens office in Kennett Square, Pennsylvania, on January 11 and 12, 2006. Based on this audit, the NRC staff concludes that: (1) the licensee had implemented NRC commitments on a timely basis; and (2) the licensee had implemented an effective program for managing NRC commitment changes.
Details of the audit are set forth in the enclosed audit report.
 
C. Crane                                       The NRC staff appreciates the resources that were available by your staff, both before and during the audit. If you have any questions, please have your staff contact me at (301) 415-1447.
Sincerely,
                                            /RA/
Farideh E. Saba, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289


==Enclosure:==
==Enclosure:==
As statedcc w/encl:  See next page Three Mile Island Nuclear Station, Unit 1 cc:
Site Vice President - Three Mile Island  Nuclear  Station, Unit 1 AmerGen Energy Company, LLC


P. O. Box 480 Middletown, PA 17057Senior Vice President -   Nuclear Services AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Vice President -   Operations, Mid-Atlantic AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348Vice President - Licensing and   Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406ChairmanBoard of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120ChairmanBoard of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057Senior Resident Inspector (TMI-1)U.S. Nuclear Regulatory Commission
As stated cc w/encl: See next page
 
Three Mile Island Nuclear Station, Unit 1 cc:
Site Vice President - Three Mile Island  Senior Resident Inspector (TMI-1)
Nuclear Station, Unit 1                U.S. Nuclear Regulatory Commission AmerGen Energy Company, LLC              P.O. Box 219 P. O. Box 480                             Middletown, PA 17057 Middletown, PA 17057 Director - Licensing and Regulatory Senior Vice President -                   Affairs Nuclear Services                       AmerGen Energy Company, LLC AmerGen Energy Company, LLC              200 Exelon Way, KSA 3-E 4300 Winfield Road                       Kennett Square, PA 19348 Warrenville, IL 60555 Director Bureau of Radiation Vice President -                         Protection Operations, Mid-Atlantic               Pennsylvania Department of AmerGen Energy Company, LLC                 Environmental Protection 200 Exelon Way, KSA 3-N                   Rachel Carson State Office Building Kennett Square, PA 19348                  P.O. Box 8469 Harrisburg, PA 17105-8469 Vice President - Licensing and Regulatory Affairs                     Plant Manager - Three Mile Island AmerGen Energy Company, LLC               Nuclear Station, Unit 1 4300 Winfield Road                       AmerGen Energy Company, LLC Warrenville, IL 60555                    P. O. Box 480 Middletown, PA 17057 Regional Administrator Region I                                 Regulatory Assurance Manager -
U.S. Nuclear Regulatory Commission         Three Mile Island Nuclear Station, 475 Allendale Road                           Unit 1 King of Prussia, PA 19406                AmerGen Energy Company, LLC P.O. Box 480 Chairman                                  Middletown, PA 17057 Board of County Commissioners of Dauphin County                       Ronald Bellamy, Region I Dauphin County Courthouse                 U.S. Nuclear Regulatory Commission Harrisburg, PA 17120                      475 Allendale Road King of Prussia, PA 19406 Chairman Board of Supervisors                     Michael A. Schoppman of Londonderry Township                 Framatome ANP R.D. #1, Geyers Church Road               Suite 705 Middletown, PA 17057                      1911 North Ft. Myer Drive Rosslyn, VA 22209
 
Three Mile Island Nuclear Station, Unit 1 cc:
Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Correspondence Control Desk AmerGen Energy Company, LLC P.O. Box 160 Kennett Square, PA 19348 Manager Licensing -
Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Assistant General Counsel AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348


P.O. Box 219 Middletown, PA  17057Director - Licensing and Regulatory        Affairs AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA  19348Director Bureau of Radiation        Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469Plant Manager - Three Mile Island          Nuclear Station, Unit 1 AmerGen Energy Company, LLC
ML060940527 OFFICE LPL1-2\PM              LPL1-2\LA            LPL1-2\BC NAME FSaba                    CRaynor              DRoberts DATE    4/18/06              4/18/06              4/18/06 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY AMERGEN ENERGY COMPANY, LLC TO THE NUCLEAR REGULATORY COMMISSION THREE MILE ISLAND NUCLEAR GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-289


P. O. Box 480 Middletown, PA  17057Regulatory Assurance Manager -    Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC
==1.0      INTRODUCTION AND BACKGROUND==


P.O. Box 480 Middletown, PA  17057Ronald Bellamy, Region IU.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA  19406Michael A. SchoppmanFramatome ANP Suite 705 1911 North Ft. Myer Drive Rosslyn, VA  22209 Three Mile Island Nuclear Station, Unit 1 cc:
On September 7, 2004, the U.S. Nuclear Regulatory Commission (NRC) published the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC, Revision 1. LIC-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance issued by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes. The current revision to LIC-105 is publicly available electronically from the Agencywide Documents Access and Management Systems (ADAMS)
Vice President, General Counsel    and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA  19101Dr. Judith JohnsrudNational Energy Committee Sierra Club 433 Orlando Avenue State College, PA  16803Eric EpsteinTMI Alert 4100 Hillsdale RoadHarrisburg, PA  17112Correspondence Control DeskAmerGen Energy Company, LLC
Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML042320463).
According to LIC-105, which cites the definition from 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. LIC-105 further 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 The audit of the Amergen Energy Company, LLC (AmerGen or the licensee) commitment management program for the Three Mile Island Nuclear Station, Unit No. 1 (TMI-1) was performed at the AmerGen offices in Kennett Square, Pennsylvania, on January 11 and 12, 2006. Since no such audit was performed prior to the issuance of LIC-105, the NRC staff defined the period covered by this audit to encompass approximately 4-to-5 years prior to the date of the audit. In accordance with LIC-105, audits consist of two major parts: (1) verification of the licensees implementation of NRC commitments that have been completed, and (2) verification of the licensees program for managing changes to NRC commitments.
Enclosure


P.O. Box 160 Kennett Square, PA  19348Manager Licensing -   Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA  19348Assistant General CounselAmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348
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 actions/activities. For commitments that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
2.1.1    Audit Scope LIC-105 limits the audit of commitments to those made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Accordingly, the audit excluded the following types of commitments:
* Commitments made on the licensees own initiative among internal organizational components.
* Commitments that pertain to milestones of licensing actions/activities (e.g., response 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.
* 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.
Prior to the audit, in order to generate a list of items for the audit, the NRC staff performed public, web-based ADAMS searches for commitments listed in licensing action and licensing activity submittals from 2000 through 2005. From this list, the NRC staff selected a representative sample of regulatory commitments to audit. The selection of the sample list covered a variety of systems, disciplines and licensing actions important to NRC staffs decision-making process. This list also included commitment changes. The NRC staff ensured that the sample selected related to the licensees licensing action and licensing activity submittals and asked the licensee to provide documentation to support the audit.
The licensee provided the documentation to support the NRC staffs audit in each of the sample areas discussed above. The licensees documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation). The attached table summarizes the licensees commitments that were audited by the NRC staff and the current status of licensee commitments.
2.1.2    Audit Results The licensees commitments are tracked by a total of three programs: Plant Information Management System Commitment Tracking, Passport, and Lotus Notes. The proliferation of tracking programs has to do with the fact that ownership of TMI-1 was acquired from the former owner and transferred to AmerGen, an Exelon subsidiary. AmerGen/Exelon is continuing the


ML060940527OFFICELPL1-2\PMLPL1-2\LALPL1-2\BCNAMEFSabaCRaynorDRobertsDATE4/18/064/18/064/18/06 EnclosureAUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATIONREGULATORY COMMITMENTS MADE BY AMERGEN ENERGY COMPANY, LLC TOTHE NUCLEAR REGULATORY COMMISSIONTHREE MILE ISLAND NUCLEAR GENERATING STATION, UNIT NO. 1DOCKET NO. 50-28
effort of converting the processes, including the commitment tracking programs, to the Exelon way. The NRC staff, therefore, aimed to ascertain that commitments had not fallen through the cracks because of multiple tracking programs, and the past transfer of ownership. During the audit, the NRC staff reviewed reports generated by all three tracking programs, and other documents related to the commitments.
The NRC staff reviewed reports generated by one or more of the three tracking programs for the commitments listed in the attached table to evaluate the status of completion. The NRC staff found that the licensees commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant procedures that had been revised as a result of commitments made by the licensee to NRC.
The NRC staff noted that some of the new/revised procedures have annotations to refer to commitments. These annotations would serve to prevent future procedure writers from inadvertently deleting or altering an item without having gone through the commitment change process. However, the older procedures have not been annotated. The licensee indicated that the former owner and operator of TMI-1 did not have requirements for commitment annotations in the procedures. The Writers Guide for Exelon TMI Procedures, Revision 6 states that this guidance, including commitments in Section 6.3 of the guidance and annotation guidance on page 13 of the guidance, is applicable to all new procedures, or procedure revisions affecting 30% or more of content, or at the discretion of the site functional area manager for revisions that affect less than 30% of content.
The NRC staff noted one instance in which a procedure that was impacted by a regulatory commitment was revised, however, the NRC was not informed. AmerGen, in its letter dated August 6, 2003, committed to improve the containment closeout inspection procedure to specifically address dirt, dust and small debris accumulation. This commitment had been originally implemented in the applicable procedure. However, subsequent to the transition to the corporate procedure, the original procedure was replaced by a new procedure. During the NRC staffs audit of the licensees regulatory commitments, the NRC staff indicated that the current procedure does not specifically address the cleanup of dirt, dust, and small debris accumulation. As a result, the licensee issued a condition report to initiate revision to the applicable procedures to ensure that dirt, dust, and small debris accumulations are appropriately addressed in the containment closeout inspections, and to flag this as a commitment.
2.2    Verification of the Licensees Program for Managing NRC Commitment Changes The NRC staff reviewed the licensees procedure entitled Commitment Management, LS-AA-110, Revision 3, against NEI 99-04. In particular, in regard to managing a change or deviation from a previously-completed commitment, Subsection 4.5.1 specifically refers to the guidance of NEI-99-04. Attachments 1 and 2 of LS-AA-110, Revision 3, provide details regarding making changes to a commitment. In general, LS-AA-110, Revision 2, follows closely the guidance of NEI-99-04: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments. The licensee submits its commitment revision report to the NRC biennially. There are no changes to the regulatory commitments that have been made during years audited by the NRC staff.


==91.0  INTRODUCTION==
In LS-AA-110, Section 3, the licensee states that the Site Vice President has overall responsibility for the commitment tracking program. Licensing director/regulatory assurance managers designate the commitment tracking coordinators that are responsible for ensuring that commitments are properly captured in a commitment tracking database (CTD). The NRC staff reviewed procedures LS-TM-110-1003, Commitment Tracking Program for Use with Lotus Notes, and LS-AA-110-1001, Commitment Tracking Program T&RM for Use with Passport, that describe the licensees commitment tracking programs and establish the responsibilities, authorities, processes, and organizational interfaces for tracking and assuring compliance with the regulatory commitments.
AND BACKGROUND On September 7, 2004, the U.S. Nuclear Regulatory Commission (NRC) published the Office ofNuclear Reactor Regulation (NRR) Office Instruction LIC-105, "Managing RegulatoryCommitments Made by Licensees to the NRC," Revision 1. LIC-105 provides the NRC staffand its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent withthe industry guidance issued by the Nuclear Energy Institute (NEI) in NEI 99-04, "Guidance for Managing NRC Commitment Changes."  The current revision to LIC-105 is publicly availableelectronically from the Agencywide Documents Access and Management Systems (ADAMS)
As set forth in Section 2.1 above, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of this review of the licensees information, as well as information from other sources, the NRC staff found no reason to differ from the licensees reported status of the audited commitments. Therefore, the NRC staff surmises that the procedures used by the licensee to manage commitments are appropriate and effective.
Public Electronic Reading Room on the Internet at the NRC web site (Accession NumberML042320463). According to LIC-105, which cites the definition from NEI-99-04, a "regulatory commitment" isan explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. LIC-105 further directs the NRR ProjectManager 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 pastlicensing 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 The audit of the Amergen Energy Company, LLC (AmerGen or the licensee) commitmentmanagement program for the Three Mile Island Nuclear Station, Unit No. 1 (TMI-1) was performed at the AmerGen offices in Kennett Square, Pennsylvania, on January 11 and 12,2006. Since no such audit was performed prior to the issuance of LIC-105, the NRC staffdefined the period covered by this audit to encompass approximately 4-to-5 years prior to the date of the audit. In accordance with LIC-105, audits consist 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. 2.1  Verification of Licensee's Implementation of NRC CommitmentsThe 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 actions/activities. For commitmentsthat had not yet been implemented, the NRC staff aimed to ascertain that they have beencaptured in an effective program for future implementation.2.1.1  Audit Scope LIC-105 limits the audit of commitments to those made in writing to the NRC as a result of pastlicensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Accordingly, the audit excluded the following types of commitments:*Commitments made on the licensee's own initiative among internal organizationalcomponents.*Commitments that pertain to milestones of licensing actions/activities (e.g., response toan NRC request for additional information by a certain date). Fulfillment of thesecommitments was indicated by the fact that the subject licensing action/activity was completed.*Commitments made as an internal reminder to take actions to comply with existingregulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by thelicensee having taken timely action in accordance with the subject requirements. Prior to the audit, in order to generate a list of items for the audit, the NRC staff performedpublic, web-based ADAMS searches for commitments listed in licensing action and licensing activity submittals from 2000 through 2005. From this list, the NRC staff selected arepresentative sample of regulatory commitments to audit. The selection of the sample list covered a variety of systems, disciplines and licensing actions important to NRC staff'sdecision-making process. This list also included commitment changes. The NRC staff ensuredthat the sample selected related to the licensee's licensing action and licensing activity submittals and asked the licensee to provide documentation to support the audit. The licensee provided the documentation to support the NRC staff's audit in each of the sampleareas discussed above. The licensee's documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation). The attached tablesummarizes the licensee's commitments that were audited by the NRC staff and the currentstatus of licensee commitments. 2.1.2 Audit Results The licensee's commitments are tracked by a total of three programs:  Plant InformationManagement System Commitment Tracking, Passport, and Lotus Notes. The proliferation of tracking programs has to do with the fact that ownership of TMI-1 was acquired from the former owner and transferred to AmerGen, an Exelon subsidiary. AmerGen/Exelon is continuing the  effort of converting the processes, including the commitment tracking programs, to the "Exelonway."  The NRC staff, therefore, aimed to ascertain that commitments had not "fallen throughthe cracks" because of multiple tracking programs, and the past transfer of ownership. Duringthe audit, the NRC staff reviewed reports generated by all three tracking programs, and otherdocuments related to the commitments.The NRC staff reviewed reports generated by one or more of the three tracking programs forthe commitments listed in the attached table to evaluate the status of completion. The NRCstaff found that the licensee's commitment tracking programs had captured all the regulatorycommitments that were identified by the NRC staff before the audit. The NRC staff alsoreviewed plant procedures that had been revised as a result of commitments made by the licensee to NRC. The NRC staff noted that some of the new/revised procedures have annotations to refer tocommitments. These annotations would serve to prevent future procedure writers from inadvertently deleting or altering an item without having gone through the commitment changeprocess. However, the older procedures have not been annotated. The licensee indicated thatthe former owner and operator of TMI-1 did not have requirements for commitment annotationsin the procedures. The "Writer's Guide for Exelon TMI Procedures," Revision 6 states that this guidance, including commitments in Section 6.3 of the guidance and annotation guidance onpage 13 of the guidance, is applicable to all new procedures, or procedure revisions affecting 30% or more of content, or at the discretion of the site functional area manager for revisions that affect less than 30% of content.The NRC staff noted one instance in which a procedure that was impacted by a regulatorycommitment was revised, however, the NRC was not informed. AmerGen, in its letter dated August 6, 2003, committed to "improve the containment closeout inspection procedure tospecifically address dirt, dust and small debris accumulation."  This commitment had been originally implemented in the applicable procedure. However, subsequent to the transition to the corporate procedure, the original procedure was replaced by a new procedure. During the NRC staff's audit of the licensee's regulatory commitments, the NRC staff indicated that thecurrent procedure does not specifically address the cleanup of dirt, dust, and small debris accumulation. As a result, the licensee issued a condition report to initiate revision to the applicable procedures to ensure that "dirt, dust, and small debris accumulations" are appropriately addressed in the containment closeout inspections, and to flag this as a commitment. 2.2  Verification of the Licensee's Program for Managing NRC Commitment C hangesThe NRC staff reviewed the licensee's procedure entitled "Commitment Management,"LS-AA-110, Revision 3, against NEI 99-04. In particular, in regard to managing a change or deviation from a previously-completed commitment, Subsection 4.5.1 specifically refers to the guidance of NEI-99-04. Attachments 1 and 2 of LS-AA-110, Revision 3, provide details regarding making changes to a commitment. In general, LS-AA-110, Revision 2, follows closely the guidance of NEI-99-04:  it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments. The licensee submits its commitment revision report to the NRC biennially. There are no changes to the regulatorycommitments that have been made during years audited by the NRC staff. In LS-AA-110, Section 3, the licensee states that the Site Vice President has overallresponsibility for the commitment tracking program. Licensing director/regulatory assurancemanagers designate the commitment tracking coordinators that are responsible for ensuringthat commitments are properly captured in a commitment tracking database (CTD). The NRC staff reviewed procedures LS-TM-110-1003, "Commitment Tracking Program for Use with Lotus Notes," and LS-AA-110-1001, "Commitment Tracking Program T&RM for Use with Passport," that describe the licensee's commitment tracking programs and establish the responsibilities, authorities, processes, and organizational interfaces for tracking and assuringcompliance with the regulatory commitments.As set forth in Section 2.1 above, the NRC staff found that the licensee had properly addressedeach regulatory commitment selected for this audit. As a result of this review of the licensee's information, as well as information from other sources, the NRC staff found no reason to differfrom the licensee's reported status of the audited commitments. Therefore, the NRC staffsurmises that the procedures used by the licensee to manage commitments are appropriate and effective.


==3.0 CONCLUSION==
==3.0     CONCLUSION==
The NRC staff concludes that, based on the above audit, (1) the licensee had implemented oris 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 AUDITD. Distel Principal Contributor:  F. E. Saba AUDITED TMI-1 COMMITMENTS(2000 THROUGH 2005) TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-05-20102May 03, 2005MB6475MC7001The proposed TMI-1 Updated Final SafetyAnalysis Report (UFSAR) updated wording will beimplemented and posted against the TMI-1 UFSAR, and then incorporated into the subsequent UFSAR.AR00180733-09Complete5928-05-20102May 03, 2005MB6475MC7001Tubes with circumferential indications in the kineticexpansions' required lengths will be removed from service upon detection - including circumferential indications that were detected during prior 1997 through 2003 outage examinations that remain in service in the kinetic expansions' required lengths.AR00180733-09CompleteFinal ECR #02-01121, Revision2, Pages 4 and 275928-05-20102May 03, 2005MB6475MC7001Implement 100% examination scope of in-servicekinetic expansions each refueling outage.AR00180733-09CompleteFinal ECR #02-01121, Revision2, Page 45928-05-20102May 03, 2005MB6475MC7001Any tubes with flaws detected in the sleeves, or inthe parent tube adjacent to the sleeve between the lower sleeve end and the parent tube kinetic expansion transition, will be plugged-on-detection.AR00180733-09CompleteFinal ECR #02-01121, Revision2, Pages 23 and 425928-03-20148RS-03-146August 06, 2003MB9620Licensed operator requalification training is inprogress and includes enhanced emergency core cooling system (ECCS) throttling criteria. All licensed operators will complete classroom training.AR00166130-05(5828-03-20148)Complete5928-03-20148RS-03-146August 06, 2003MB9620The plant will improve the containment closeoutinspection procedure to specifically address dirt, dust, and small debris accumulation.AR00166130-05(5828-03-20148)See AR00443432  TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-03-20148RS-03-146August 06, 2003MB9620The plant will develop a specific procedure forcleaning and inspecting the floor drains in containment and will coordinate this work with the containment closeout procedure.AR00166130-07(5828-03-20148)CompleteProcedure 661-OPS-4550-03, Revision 1 and Operating Procedure Number 1101-05, Revision 45928-05-20223August 18 2005MB9620TMI-1 will revise the site emergency operatingprocedures (EOP) to incorporate interim measures to include initiating borated water storage tank (BWST) refill after switch-over to recirculation from the containment sump.AR0282077-13(5828-05-10223)Complete5928-05-20223August 18 2005MB9620TMI-1 will develop a written guideline that willcover re-injecting additional inventory from the BWST. This will include guidance for injecting more than one BWST volume from a refilled BWST or for injecting alternate water sources. AR0282077-14(5828-05-10223)Supplemented by September 26,2005 letter commitment5928-05-20269September 26, 2005MB9620In response to Bulletin 2003-01, TMI-1 will developa written guideline that will cover re-injecting additional inventory from the BWST. This will include guidance for injecting more than one BWST volume from a refilled BWST or for injecting alternate water sources. AR0282077-14(5828-05-10269)CompleteER-TM-TSC-1018, Revision 0 Note:  The cited procedures is annotated (marked with CM-1). 5928-05-20076RS-05-021March 7, 2005MC4724If a strainer modification is required, TMI-1 willcomplete a preliminary debris loss analysis by September 1, 2005. The final debris head loss analysis will be completed as part of the strainer modification in accordance with the NRC schedule for GSI-191 resolution, and this analysis will include any additional impact found in the containment walkdown to be performed in November 2005.AR00282077-08AR00282077-09 AR00282077-10 (5828-05-20076)In progress:  Scheduledcompletion date December 31, 2007 Calculations completed Walkdown completed  TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-05-20249RS-03-116September 1, 2005MC4724The recirculation function for the ECCS and thebuilding spray (BS) system for TMI-1, will be in compliance with the regulatory requirements section of the subject generic letter under debris loading conditions by December 31, 2007.AR00282077-19(5828-05-20249)In progress:  Scheduledcompletion date December 31, 20075928-05-20249RS-03-116September 1, 2005MC4724Overall completion of the downstream effectsevaluation, including the fuel impact under the current WCAP guidance, will occur by January 31, 2006.AR00282077-20(5828-05-20249)In progress when audited:Scheduled completion date January 31, 20065928-05-20249RS-03-116September 1, 2005MC4724The chemical effects evaluation (excluding vendortesting) will be completed by January 31, 2006 forTMI-1.AR00282077-23(5828-05-20249)In progress when audited:Scheduled completion date January 31, 20065928-05-20249RS-03-116September 1, 2005MC4724TMI-1 will validate that adequate margin exists tobound the impact of chemical effects once the vendors' tests results to quantify chemical debris effect on head loss have been published.
AmerGen will update the TMI-1 NRC ProjectManager with this scheduling information when the vendors have formulated their testing schedule.AR00282077-26(5828-05-20249)In progress:  Scheduledcompletion within 3 months after vendor test results are published 5928-04-20162October 20, 2004MC4904TMI-1 administrative controls will require:  thatqualified personnel be designated; that required tools or equipment be identified and staged; and that required guidance be provided to ensure that, in the event of a fuel handling accident inside containment, containment equipment hatch closure is achieved within 45 minutes following an evacuation of the containment. Such prompt closure methods need not completely block the equipment hatch opening or be capable of resisting pressure.AR00235958-5CompleteProcedure 1101-3, Sections7.3.1.6.1 and 7.3.1.6.2  TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-04-20162October 20, 2004MC4904TMI-1 will have procedures in place, which willrequire operation of the Reactor Building Purge Exhaust System and bypassing of the Reactor Building Purge High Radiation isolation signal whenever irradiated fuel movement is in progress and containment integrity is not maintained.
Operation of the Reactor Building Purge Exhaust System is a contingency action, which will decrease doses even further by drawing any release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored.AR00235958-5CompleteProcedure 1101-3, Section 7.3.1.6.3 OP-TM-823-408, Section 4.3 Procedure 1505-1, Datasheet 1, Item F5928-04-20162October 20, 2004MC4904TMI-1 will have procedures in place which willrequire the placement of continuously-operated particulate and radioiodine air sampling equipment inboard of the open containment equipment hatch opening during fuel loading and refueling activities.AR00235958-5CompleteProcedure 1101-3, Section7.3.1.6.45928-05-20253September 19, 2005MC4904Procedural controls will ensure that during themovement of irradiated fuel the equipment hatch/missile shield area will be manned 24 hours/day, 7 days/week in support of the outage unless the equipment hatch is closed and four bolts are installed.AR00235958-12CompleteProcedure 1101-3, Section7.3.1.6.25928-05-20253September 19, 2005MC4904Complete permanent installation of steel plate tothe lower-most missile shield carriage area. The added steel plate will cover the area where grating is currently installed.AR00235958-13CompleteA walkdown performed at 14:00on October 25, 2005 found the installation of structural components met ECR 05-00382 requirements. TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-05-20253September 19, 2005MC4904Prior to initial use of this Technical Specification,TMI-1 will demonstrate that the 45-minute closure duration is achievable.AR00235958-14CompleteProcedure MA-TM-156-900,Revision 0 and W/O C20108995928-05-20253September 19, 2005MC4904TMI-1 procedures will include the followingrequirements to ensure that General Design Criterion (GDC)-64 Ti R16 requirements will continue to be met during the movement of irradiated fuel:
: 1)  If the reactor building equipment hatch is removed (open), then place the purge system in operation and control the air flow at the hatch so that the prevailing continuous direction of air flow is into the reactor building.
: 2)  If the condition, as described in Item 1 above, cannot be maintained, then fuel handling operations will be terminated until the reactor building equipment hatch is closed or purge is restored.
: 3)  Whenever the purge system is operating, then ensure purge exhaust radiation monitor is operable or obtain periodic samples as currently specified in the Offsite Dose Calculation Manual.
: 4)  Whenever the hatch is open, position a portable radiation monitor at the reactor building equipment hatch opening.
: 5)  If the purge system is operated with the reactor building equipment hatch open, then bypass the reactor building purge exhaust high radiation interlock.
: 6)  Prior to initiating irradiated fuel movement with the reactor building equipment.AR00235958-5CompleteRequirements 1, 2 & 4 inProcedure 1101-3 Requirements 3 & 5 in OP-TM-823-408 Requirement 6 in Procedure 1505-1  TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-02-20152(LER 2002-002-


00)July 26, 2002Establish a specification for contact area betweenthe upper spring washer and spring. The specification will be established prior to the next refueling outage.AR 00110749-17CompleteSpecification SP- 1101-12-020,Revision 8, Section 4.8.25928-02-20152(LER 2002-002-
The NRC staff concludes that, based on the above audit, (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 D. Distel Principal Contributor: F. E. Saba


00)July 26, 2002The rebuilt valve will be retested after one r oundtrip of normal shipping prior to use.AR 00110749-18CompleteSubject pressurizer safety code satisfactorily tested on November 18, 2002.5928-02-20062(LER 2002-001-
AUDITED TMI-1 COMMITMENTS (2000 THROUGH 2005)
TMI-1 Submittal Submittal    NRC    Summary of Commitment                                TMI-1 Tracking  Implementation Status Date        TAC No.                                                      Number 5928-05-20102  May 03, 2005 MB6475  The proposed TMI-1 Updated Final Safety              AR00180733-09  Complete MC7001  Analysis Report (UFSAR) updated wording will be implemented and posted against the TMI-1 UFSAR, and then incorporated into the subsequent UFSAR.
5928-05-20102  May 03, 2005 MB6475  Tubes with circumferential indications in the kinetic AR00180733-09  Complete MC7001  expansions required lengths will be removed from service upon detection - including circumferential                    Final ECR #02-01121, Revision indications that were detected during prior 1997                      2, Pages 4 and 27 through 2003 outage examinations that remain in service in the kinetic expansions required lengths.
5928-05-20102  May 03, 2005 MB6475  Implement 100% examination scope of in-service        AR00180733-09  Complete MC7001  kinetic expansions each refueling outage.
Final ECR #02-01121, Revision 2, Page 4 5928-05-20102  May 03, 2005 MB6475  Any tubes with flaws detected in the sleeves, or in  AR00180733-09  Complete MC7001  the parent tube adjacent to the sleeve between the lower sleeve end and the parent tube kinetic                          Final ECR #02-01121, Revision expansion transition, will be plugged-on-detection.                   2, Pages 23 and 42 5928-03-20148  August 06,   MB9620  Licensed operator requalification training is in      AR00166130-05  Complete RS-03-146      2003                progress and includes enhanced emergency core        (5828-03-20148) cooling system (ECCS) throttling criteria. All licensed operators will complete classroom training.
5928-03-20148  August 06,  MB9620  The plant will improve the containment closeout      AR00166130-05  See AR00443432 RS-03-146      2003                inspection procedure to specifically address dirt,    (5828-03-20148) dust, and small debris accumulation.


00)March 15, 2002Update drawings/vendor manual to reflect actualconfiguration.AR00090391-16CompleteECR 02-00504 was issued to update drawings and revise vendor manual VM-TM-01725928-02-20062(LER 2002-001-
TMI-1 Submittal Submittal    NRC    Summary of Commitment                                TMI-1 Tracking  Implementation Status Date          TAC No.                                                      Number 5928-03-20148  August 06,    MB9620  The plant will develop a specific procedure for      AR00166130-07  Complete RS-03-146      2003                  cleaning and inspecting the floor drains in          (5828-03-20148) Procedure 661-OPS-4550-03, containment and will coordinate this work with the                    Revision 1 and Operating containment closeout procedure.                                      Procedure Number 1101-05, Revision 4 5928-05-20223  August 18    MB9620  TMI-1 will revise the site emergency operating        AR0282077-13    Complete 2005                  procedures (EOP) to incorporate interim measures      (5828-05-10223) to include initiating borated water storage tank (BWST) refill after switch-over to recirculation from the containment sump.
5928-05-20223  August 18    MB9620  TMI-1 will develop a written guideline that will      AR0282077-14    Supplemented by September 26, 2005                  cover re-injecting additional inventory from the      (5828-05-10223) 2005 letter commitment BWST. This will include guidance for injecting more than one BWST volume from a refilled BWST or for injecting alternate water sources.
5928-05-20269  September 26, MB9620  In response to Bulletin 2003-01, TMI-1 will develop  AR0282077-14    Complete 2005                  a written guideline that will cover re-injecting      (5828-05-10269) ER-TM-TSC-1018, Revision 0 additional inventory from the BWST. This will                        Note: The cited procedures is include guidance for injecting more than one                          annotated (marked with CM-1).
BWST volume from a refilled BWST or for injecting alternate water sources.
5928-05-20076  March 7, 2005 MC4724  If a strainer modification is required, TMI-1 will    AR00282077-08  In progress: Scheduled RS-05-021                            complete a preliminary debris loss analysis by        AR00282077-09  completion date December 31, September 1, 2005. The final debris head loss        AR00282077-10  2007 analysis will be completed as part of the strainer    (5828-05-20076) Calculations completed modification in accordance with the NRC schedule                      Walkdown completed for GSI-191 resolution, and this analysis will include any additional impact found in the containment walkdown to be performed in November 2005.


00)March 15, 2002Complete the installation of 480/460 VACtransformers for each inventor.PIMS C2004-237, 299, 300, 301, 302 (A2024085)Complete5928-02-20062(LER 2002-001-
TMI-1 Submittal Submittal    NRC    Summary of Commitment                              TMI-1 Tracking  Implementation Status Date        TAC No.                                                    Number 5928-05-20249  September 1, MC4724  The recirculation function for the ECCS and the    AR00282077-19  In progress: Scheduled RS-03-116      2005                building spray (BS) system for TMI-1, will be in  (5828-05-20249) completion date December 31, compliance with the regulatory requirements                        2007 section of the subject generic letter under debris loading conditions by December 31, 2007.
5928-05-20249  September 1, MC4724  Overall completion of the downstream effects      AR00282077-20  In progress when audited:
RS-03-116      2005                evaluation, including the fuel impact under the    (5828-05-20249) Scheduled completion date current WCAP guidance, will occur by January 31,                  January 31, 2006 2006.
5928-05-20249  September 1, MC4724  The chemical effects evaluation (excluding vendor  AR00282077-23  In progress when audited:
RS-03-116      2005                testing) will be completed by January 31, 2006 for (5828-05-20249) Scheduled completion date TMI-1.                                                            January 31, 2006 5928-05-20249  September 1, MC4724  TMI-1 will validate that adequate margin exists to AR00282077-26  In progress: Scheduled RS-03-116      2005                bound the impact of chemical effects once the      (5828-05-20249) completion within 3 months after vendors tests results to quantify chemical debris                vendor test results are published effect on head loss have been published.
AmerGen will update the TMI-1 NRC Project Manager with this scheduling information when the vendors have formulated their testing schedule.
5928-04-20162  October 20,  MC4904  TMI-1 administrative controls will require: that  AR00235958-5    Complete 2004                qualified personnel be designated; that required tools or equipment be identified and staged; and                  Procedure 1101-3, Sections that required guidance be provided to ensure that,                7.3.1.6.1 and 7.3.1.6.2 in the event of a fuel handling accident inside containment, containment equipment hatch closure is achieved within 45 minutes following an evacuation of the containment. Such prompt closure methods need not completely block the equipment hatch opening or be capable of resisting pressure.


00)March 15, 2002Verify the current procurement process willprevent this type of error (the original design of power supplies to the vital power buses did not meet certain design specifications.)AR00090391-16CompleteThe current procurement process provides an improved technical review prior to order, access to the evaluated vendor's list and improved quality assurance inspection. TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-01-20283October 18, 2001MC2336The following commitment will be included as aCategory A commitment in the "Plan for the Long Range Planning Program for the Three Mile Island Nuclear Station -Unit 1" as provided in TMI-1 Operating License Condition No. 2.c(9).
TMI-1 Submittal Submittal    NRC    Summary of Commitment                                TMI-1 Tracking Implementation Status Date          TAC No.                                                      Number 5928-04-20162  October 20,  MC4904  TMI-1 will have procedures in place, which will      AR00235958-5  Complete 2004                  require operation of the Reactor Building Purge Exhaust System and bypassing of the Reactor                          Procedure 1101-3, Section Building Purge High Radiation isolation signal                      7.3.1.6.3 whenever irradiated fuel movement is in progress                    OP-TM-823-408, Section 4.3 and containment integrity is not maintained.                        Procedure 1505-1, Datasheet 1, Operation of the Reactor Building Purge Exhaust                      Item F System is a contingency action, which will decrease doses even further by drawing any release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored.
"A minimum Reactor Coolant System (RCS) flow rate of 105.5% of design flow (105.5% of 352,000 gpm) is specified to offset potential mixed core DNBR [departure from nucleate boiling ratio]
5928-04-20162  October 20,  MC4904  TMI-1 will have procedures in place which will        AR00235958-5  Complete 2004                  require the placement of continuously-operated particulate and radioiodine air sampling equipment                  Procedure 1101-3, Section inboard of the open containment equipment hatch                      7.3.1.6.4 opening during fuel loading and refueling activities.
penalty for TMI-1 Cycle 14 and any subsequent cycle. This commitment expires when a mixed core penalty is no longer required or NRC-approved statistical core design methods are utilized which provide an alternative means of addressing transition core effects."This commitment was removedby Amendment No. 250, issued July 7, 2004. 5928-01-20255September 17, 2001MB1051TMI-1 administrative controls will require: thatqualified 1 R14 personnel be designated; that required tools or equipment be identified and staged; and that required guidance be provided to ensure that containment closure is achieved within 45 minutes following the decision to isolate containment.CompleteProcedure MA-TM-156-900, Revision 0 and W/O C20108995928-01-20255September 17, 2001MB1051The following commitment will be included as aCategory A 1 R14 commitment in the "Plan for the Long Range Planning Program for the Three Mile Island Nuclear Station -Unit 1" as provided in TMI-1 Operating License Condition No. 2.c(9),
5928-05-20253  September 19, MC4904  Procedural controls will ensure that during the      AR00235958-12  Complete 2005                  movement of irradiated fuel the equipment hatch/missile shield area will be manned 24                          Procedure 1101-3, Section hours/day, 7 days/week in support of the outage                      7.3.1.6.2 unless the equipment hatch is closed and four bolts are installed.
5928-05-20253  September 19, MC4904  Complete permanent installation of steel plate to    AR00235958-13  Complete 2005                  the lower-most missile shield carriage area. The added steel plate will cover the area where grating                  A walkdown performed at 14:00 is currently installed.                                              on October 25, 2005 found the installation of structural components met ECR 05-00382 requirements.
 
TMI-1 Submittal Submittal    NRC    Summary of Commitment                                TMI-1 Tracking Implementation Status Date          TAC No.                                                      Number 5928-05-20253  September 19, MC4904  Prior to initial use of this Technical Specification, AR00235958-14  Complete 2005                  TMI-1 will demonstrate that the 45-minute closure duration is achievable.                                              Procedure MA-TM-156-900, Revision 0 and W/O C2010899 5928-05-20253  September 19, MC4904  TMI-1 procedures will include the following          AR00235958-5  Complete 2005                  requirements to ensure that General Design Criterion (GDC)-64 Ti R16 requirements will                          Requirements 1, 2 & 4 in continue to be met during the movement of                            Procedure 1101-3 irradiated fuel:                                                    Requirements 3 & 5 in
: 1) If the reactor building equipment hatch is                        OP-TM-823-408 removed (open), then place the purge system in                      Requirement 6 in Procedure operation and control the air flow at the hatch so                  1505-1 that the prevailing continuous direction of air flow is into the reactor building.
: 2) If the condition, as described in Item 1 above, cannot be maintained, then fuel handling operations will be terminated until the reactor building equipment hatch is closed or purge is restored.
: 3) Whenever the purge system is operating, then ensure purge exhaust radiation monitor is operable or obtain periodic samples as currently specified in the Offsite Dose Calculation Manual.
: 4) Whenever the hatch is open, position a portable radiation monitor at the reactor building equipment hatch opening.
: 5) If the purge system is operated with the reactor building equipment hatch open, then bypass the reactor building purge exhaust high radiation interlock.
: 6) Prior to initiating irradiated fuel movement with the reactor building equipment.
 
TMI-1 Submittal Submittal    NRC    Summary of Commitment                              TMI-1 Tracking Implementation Status Date          TAC No.                                                    Number 5928-02-20152  July 26, 2002        Establish a specification for contact area between  AR 00110749-17 Complete (LER 2002-002-                        the upper spring washer and spring. The
: 00)                                  specification will be established prior to the next                Specification SP- 1101-12-020, refueling outage.                                                  Revision 8, Section 4.8.2 5928-02-20152  July 26, 2002        The rebuilt valve will be retested after one round  AR 00110749-18 Complete (LER 2002-002-                        trip of normal shipping prior to use.                              Subject pressurizer safety code
: 00)                                                                                                     satisfactorily tested on November 18, 2002.
5928-02-20062  March 15,             Update drawings/vendor manual to reflect actual    AR00090391-16  Complete (LER 2002-001-  2002                  configuration.                                                    ECR 02-00504 was issued to
: 00)                                                                                                      update drawings and revise vendor manual VM-TM-0172 5928-02-20062  March 15,            Complete the installation of 480/460 VAC            PIMS C2004-    Complete (LER 2002-001-  2002                  transformers for each inventor.                    237, 299, 300,
: 00)                                                                                      301, 302 (A2024085) 5928-02-20062  March 15,            Verify the current procurement process will        AR00090391-16  Complete (LER 2002-001-  2002                  prevent this type of error (the original design of                 The current procurement process
: 00)                                  power supplies to the vital power buses did not                   provides an improved technical meet certain design specifications.)                               review prior to order, access to the evaluated vendors list and improved quality assurance inspection.
 
TMI-1 Submittal Submittal    NRC     Summary of Commitment                                TMI-1 Tracking Implementation Status Date          TAC No.                                                      Number 5928-01-20283  October 18,   MC2336  The following commitment will be included as a                      This commitment was removed 2001                  Category A commitment in the "Plan for the Long                     by Amendment No. 250, issued Range Planning Program for the Three Mile Island                   July 7, 2004.
Nuclear Station -Unit 1" as provided in TMI-1 Operating License Condition No. 2.c(9).
                                      "A minimum Reactor Coolant System (RCS) flow rate of 105.5% of design flow (105.5% of 352,000 gpm) is specified to offset potential mixed core DNBR [departure from nucleate boiling ratio]
penalty for TMI-1 Cycle 14 and any subsequent cycle. This commitment expires when a mixed core penalty is no longer required or NRC-approved statistical core design methods are utilized which provide an alternative means of addressing transition core effects."
5928-01-20255  September 17, MB1051  TMI-1 administrative controls will require: that                    Complete 2001                  qualified 1 R14 personnel be designated; that                       Procedure MA-TM-156-900, required tools or equipment be identified and                       Revision 0 and W/O C2010899 staged; and that required guidance be provided to ensure that containment closure is achieved within 45 minutes following the decision to isolate containment.
5928-01-20255  September 17, MB1051  The following commitment will be included as a                      Complete 2001                  Category A 1 R14 commitment in the "Plan for the                   AmerGen Submittal Long Range Planning Program for the Three Mile                     5928-01-20342, dated Island Nuclear Station -Unit 1" as provided in                     December 13, 2001 TMI-1 Operating License Condition No. 2.c(9),
prior to the start of the TMI-1 1R14 outage.
prior to the start of the TMI-1 1R14 outage.
"When handling irradiated fuel in the reactor building, a shiftly check and a daily verification (once per 24 hours) shall be performed to confirm that the Fuel Transfer Canal water level is >23 feet above the reactor vessel flange (Technical Specification 3.8.11)."CompleteAmerGen Submittal 5928-01-20342, dated December 13, 2001  TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-01-20108April 11, 2001MB1013Subsequent to the TMI-1 14R refueling outage fuelassembly Post Irradiation Examinations (PIE),
When handling irradiated fuel in the reactor building, a shiftly check and a daily verification (once per [[estimated NRC review hours::24 hours]]) shall be performed to confirm that the Fuel Transfer Canal water level is >23 feet above the reactor vessel flange (Technical Specification 3.8.11).
AmerGen will provide the NRC the results of thePIE data obtained for the M5 lead test rods. At that time AmerGen will also provide to the NRC confirmation of the results of the TMI-1 Cycle 14 specific fuel rod design analysis for the M5 lead test rods performed to determine acceptability for use in Cycle 14. If fuel rod behavior, as observed in the PIE, is not as expected or if analysis does not confirm fuel rod design criteria are met, then the M5 lead test rods will not be used in Cycle 14. AmerGen will also provide the NRC the dataobtained from PIE performed on the M5 lead test rods at the conclusion of TMI-1 operating Cycle 14.ETTS Task Nos.40816 and 40816-1CompleteAmerGen submittal 5928-02-20120, dated May 20, 2002  (refueling outage 14)
 
AmerGen submittal 5928-05-20074, dated March 15, 2005  (refueling outage 15)5928-00-20280September 8, 2000Ensuring the adequacy of the acceptance criteriafor the daily operability surveillance check of the makeup tank pressure instrument.5928-00-20280.001CompleteCommitment added to Technical Specification 4.1 bases (Page 4-2)5928-04-20095April 23, 2004MC2760AmerGen will develop and maintain contingencyplans for obtaining and analyzing highly radioactive samples from the RCS, containment sump, and containment atmosphere. The contingency plans will be contained in the TMI-1 chemistry procedures and implementation will be completed with the implementation of the license amendment. Establishment and maintenance of contingency plans is considered a regulatory commitment.AR00220236-11AR00220236-13CompleteChemistry procedures N1830
TMI-1 Submittal Submittal      NRC     Summary of Commitment                              TMI-1 Tracking Implementation Status Date          TAC No.                                                    Number 5928-01-20108  April 11, 2001 MB1013  Subsequent to the TMI-1 14R refueling outage fuel  ETTS Task Nos. Complete assembly Post Irradiation Examinations (PIE),       40816 and      AmerGen submittal AmerGen will provide the NRC the results of the    40816-1        5928-02-20120, dated May 20, PIE data obtained for the M5 lead test rods. At                   2002 (refueling outage 14) that time AmerGen will also provide to the NRC                     AmerGen submittal confirmation of the results of the TMI-1 Cycle 14                 5928-05-20074, dated March 15, specific fuel rod design analysis for the M5 lead                 2005 (refueling outage 15) test rods performed to determine acceptability for use in Cycle 14. If fuel rod behavior, as observed in the PIE, is not as expected or if analysis does not confirm fuel rod design criteria are met, then the M5 lead test rods will not be used in Cycle 14.
AmerGen will also provide the NRC the data obtained from PIE performed on the M5 lead test rods at the conclusion of TMI-1 operating Cycle 14.
5928-00-20280  September 8,           Ensuring the adequacy of the acceptance criteria    5928      Complete 2000                  for the daily operability surveillance check of the 20280.001      Commitment added to Technical makeup tank pressure instrument.                                   Specification 4.1 bases (Page 4-2) 5928-04-20095  April 23, 2004 MC2760  AmerGen will develop and maintain contingency      AR00220236-11  Complete plans for obtaining and analyzing highly           AR00220236-13  Chemistry procedures N1830 radioactive samples from the RCS, containment                     N1831 sump, and containment atmosphere. The contingency plans will be contained in the TMI-1 chemistry procedures and implementation will be completed with the implementation of the license amendment. Establishment and maintenance of contingency plans is considered a regulatory commitment.


N1831  TMI-1 SubmittalSubmittalDate NRC TAC No.Summary of CommitmentTMI-1 Tracking NumberImplementation Status5928-04-20095April 23, 2004MC2760The capability for classifying fuel damage eventsat the alert level threshold will be established for TMI-1 at radioactivity levels of 300 micro CVcc dose equivalent iodine. This capability will be described in the TMI-1 emergency plan and emergency plan implementing procedures and implementation will be completed with the implementation of the license amendment. The capability for classifying fuel damage events is considered a regulatory commitment.AR00220236-08CompleteCapability was identified in the TMI-1 emergency plan.5928-04-20095April 23, 2004MC2760AmerGen has verified that it has established theability to assess radioactive iodines released to offsite environs. The capability for monitoring iodines will be maintained within the TMI-1 emergency plan and emergency plan implementing procedures. Implementation of this commitment is complete. The capability to monitor radioactive iodines is considered a regulatory commitment.AR 00220236-15CompleteCapability was identified in the TMI-1 emergency plan.5928-04-20065October 20, 2004MC2760The as-found and as-left values will continue to berecorded and reviewed for consistency with the assumptions of the surveillance interval extension analysis. The review will verify the test results meet acceptance criteria. Out-of-tolerance results will be evaluated to determine if they meet the requirements outlined in BAW-10167.AR 00235945-03AR 00235945-06To be completed by February 28,2006 (not completed during the audit)}}
TMI-1 Submittal Submittal      NRC     Summary of Commitment                                TMI-1 Tracking Implementation Status Date          TAC No.                                                      Number 5928-04-20095  April 23, 2004 MC2760  The capability for classifying fuel damage events    AR00220236-08  Complete at the alert level threshold will be established for               Capability was identified in the TMI-1 at radioactivity levels of 300 micro CVcc                     TMI-1 emergency plan.
dose equivalent iodine. This capability will be described in the TMI-1 emergency plan and emergency plan implementing procedures and implementation will be completed with the implementation of the license amendment. The capability for classifying fuel damage events is considered a regulatory commitment.
5928-04-20095  April 23, 2004 MC2760  AmerGen has verified that it has established the    AR 00220236-15 Complete ability to assess radioactive iodines released to                   Capability was identified in the offsite environs. The capability for monitoring                     TMI-1 emergency plan.
iodines will be maintained within the TMI-1 emergency plan and emergency plan implementing procedures. Implementation of this commitment is complete. The capability to monitor radioactive iodines is considered a regulatory commitment.
5928-04-20065  October 20,   MC2760  The as-found and as-left values will continue to be  AR 00235945-03 To be completed by February 28, 2004                  recorded and reviewed for consistency with the      AR 00235945-06 2006 (not completed during the assumptions of the surveillance interval extension                 audit) analysis. The review will verify the test results meet acceptance criteria. Out-of-tolerance results will be evaluated to determine if they meet the requirements outlined in BAW-10167.}}

Latest revision as of 08:00, 14 March 2020

Nuclear Station - Audit of the Licensee'S Management of Regulatory Commitments
ML060940527
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 04/18/2006
From: Farideh Saba
Plant Licensing Branch III-2
To: Crane C
AmerGen Energy Co
Saba F 301-465-1447
References
TAC MC8310
Download: ML060940527 (18)
v • d • e


Text

April 18, 2006 Mr. Christopher M. Crane President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC8310)

Dear Mr. Crane:

The Nuclear Regulatory Commission (NRC) staff is required to audit a licensees commitment management program once every 3 years, in accordance with the NRC Office of Nuclear Reactor Regulation Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management Systems Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML042320463), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes.

An audit of AmerGen Energy Company, LLCs (AmerGens) commitment management program for the Three Mile Island Nuclear Station, Unit No. 1 was performed at AmerGens office in Kennett Square, Pennsylvania, on January 11 and 12, 2006. Based on this audit, the NRC staff concludes that: (1) the licensee had implemented NRC commitments on a timely basis; and (2) the licensee had implemented an effective program for managing NRC commitment changes.

Details of the audit are set forth in the enclosed audit report.

C. Crane The NRC staff appreciates the resources that were available by your staff, both before and during the audit. If you have any questions, please have your staff contact me at (301) 415-1447.

Sincerely,

/RA/

Farideh E. Saba, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc w/encl: See next page

Three Mile Island Nuclear Station, Unit 1 cc:

Site Vice President - Three Mile Island Senior Resident Inspector (TMI-1)

Nuclear Station, Unit 1 U.S. Nuclear Regulatory Commission AmerGen Energy Company, LLC P.O. Box 219 P. O. Box 480 Middletown, PA 17057 Middletown, PA 17057 Director - Licensing and Regulatory Senior Vice President - Affairs Nuclear Services AmerGen Energy Company, LLC AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E 4300 Winfield Road Kennett Square, PA 19348 Warrenville, IL 60555 Director Bureau of Radiation Vice President - Protection Operations, Mid-Atlantic Pennsylvania Department of AmerGen Energy Company, LLC Environmental Protection 200 Exelon Way, KSA 3-N Rachel Carson State Office Building Kennett Square, PA 19348 P.O. Box 8469 Harrisburg, PA 17105-8469 Vice President - Licensing and Regulatory Affairs Plant Manager - Three Mile Island AmerGen Energy Company, LLC Nuclear Station, Unit 1 4300 Winfield Road AmerGen Energy Company, LLC Warrenville, IL 60555 P. O. Box 480 Middletown, PA 17057 Regional Administrator Region I Regulatory Assurance Manager -

U.S. Nuclear Regulatory Commission Three Mile Island Nuclear Station, 475 Allendale Road Unit 1 King of Prussia, PA 19406 AmerGen Energy Company, LLC P.O. Box 480 Chairman Middletown, PA 17057 Board of County Commissioners of Dauphin County Ronald Bellamy, Region I Dauphin County Courthouse U.S. Nuclear Regulatory Commission Harrisburg, PA 17120 475 Allendale Road King of Prussia, PA 19406 Chairman Board of Supervisors Michael A. Schoppman of Londonderry Township Framatome ANP R.D. #1, Geyers Church Road Suite 705 Middletown, PA 17057 1911 North Ft. Myer Drive Rosslyn, VA 22209

Three Mile Island Nuclear Station, Unit 1 cc:

Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Correspondence Control Desk AmerGen Energy Company, LLC P.O. Box 160 Kennett Square, PA 19348 Manager Licensing -

Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Assistant General Counsel AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348

ML060940527 OFFICE LPL1-2\PM LPL1-2\LA LPL1-2\BC NAME FSaba CRaynor DRoberts DATE 4/18/06 4/18/06 4/18/06 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY AMERGEN ENERGY COMPANY, LLC TO THE NUCLEAR REGULATORY COMMISSION THREE MILE ISLAND NUCLEAR GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-289

1.0 INTRODUCTION AND BACKGROUND

On September 7, 2004, the U.S. Nuclear Regulatory Commission (NRC) published the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC, Revision 1. LIC-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC staff by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance issued by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes. The current revision to LIC-105 is publicly available electronically from the Agencywide Documents Access and Management Systems (ADAMS)

Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML042320463).

According to LIC-105, which cites the definition from 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. LIC-105 further 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 The audit of the Amergen Energy Company, LLC (AmerGen or the licensee) commitment management program for the Three Mile Island Nuclear Station, Unit No. 1 (TMI-1) was performed at the AmerGen offices in Kennett Square, Pennsylvania, on January 11 and 12, 2006. Since no such audit was performed prior to the issuance of LIC-105, the NRC staff defined the period covered by this audit to encompass approximately 4-to-5 years prior to the date of the audit. In accordance with LIC-105, audits consist of two major parts: (1) verification of the licensees implementation of NRC commitments that have been completed, and (2) verification of the licensees program for managing changes to NRC commitments.

Enclosure

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 actions/activities. For commitments that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.

2.1.1 Audit Scope LIC-105 limits the audit of commitments to those made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Accordingly, the audit excluded the following types of commitments:

  • Commitments made on the licensees own initiative among internal organizational components.
  • Commitments that pertain to milestones of licensing actions/activities (e.g., response 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.
  • 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.

Prior to the audit, in order to generate a list of items for the audit, the NRC staff performed public, web-based ADAMS searches for commitments listed in licensing action and licensing activity submittals from 2000 through 2005. From this list, the NRC staff selected a representative sample of regulatory commitments to audit. The selection of the sample list covered a variety of systems, disciplines and licensing actions important to NRC staffs decision-making process. This list also included commitment changes. The NRC staff ensured that the sample selected related to the licensees licensing action and licensing activity submittals and asked the licensee to provide documentation to support the audit.

The licensee provided the documentation to support the NRC staffs audit in each of the sample areas discussed above. The licensees documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation). The attached table summarizes the licensees commitments that were audited by the NRC staff and the current status of licensee commitments.

2.1.2 Audit Results The licensees commitments are tracked by a total of three programs: Plant Information Management System Commitment Tracking, Passport, and Lotus Notes. The proliferation of tracking programs has to do with the fact that ownership of TMI-1 was acquired from the former owner and transferred to AmerGen, an Exelon subsidiary. AmerGen/Exelon is continuing the

effort of converting the processes, including the commitment tracking programs, to the Exelon way. The NRC staff, therefore, aimed to ascertain that commitments had not fallen through the cracks because of multiple tracking programs, and the past transfer of ownership. During the audit, the NRC staff reviewed reports generated by all three tracking programs, and other documents related to the commitments.

The NRC staff reviewed reports generated by one or more of the three tracking programs for the commitments listed in the attached table to evaluate the status of completion. The NRC staff found that the licensees commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant procedures that had been revised as a result of commitments made by the licensee to NRC.

The NRC staff noted that some of the new/revised procedures have annotations to refer to commitments. These annotations would serve to prevent future procedure writers from inadvertently deleting or altering an item without having gone through the commitment change process. However, the older procedures have not been annotated. The licensee indicated that the former owner and operator of TMI-1 did not have requirements for commitment annotations in the procedures. The Writers Guide for Exelon TMI Procedures, Revision 6 states that this guidance, including commitments in Section 6.3 of the guidance and annotation guidance on page 13 of the guidance, is applicable to all new procedures, or procedure revisions affecting 30% or more of content, or at the discretion of the site functional area manager for revisions that affect less than 30% of content.

The NRC staff noted one instance in which a procedure that was impacted by a regulatory commitment was revised, however, the NRC was not informed. AmerGen, in its letter dated August 6, 2003, committed to improve the containment closeout inspection procedure to specifically address dirt, dust and small debris accumulation. This commitment had been originally implemented in the applicable procedure. However, subsequent to the transition to the corporate procedure, the original procedure was replaced by a new procedure. During the NRC staffs audit of the licensees regulatory commitments, the NRC staff indicated that the current procedure does not specifically address the cleanup of dirt, dust, and small debris accumulation. As a result, the licensee issued a condition report to initiate revision to the applicable procedures to ensure that dirt, dust, and small debris accumulations are appropriately addressed in the containment closeout inspections, and to flag this as a commitment.

2.2 Verification of the Licensees Program for Managing NRC Commitment Changes The NRC staff reviewed the licensees procedure entitled Commitment Management, LS-AA-110, Revision 3, against NEI 99-04. In particular, in regard to managing a change or deviation from a previously-completed commitment, Subsection 4.5.1 specifically refers to the guidance of NEI-99-04. Attachments 1 and 2 of LS-AA-110, Revision 3, provide details regarding making changes to a commitment. In general, LS-AA-110, Revision 2, follows closely the guidance of NEI-99-04: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments. The licensee submits its commitment revision report to the NRC biennially. There are no changes to the regulatory commitments that have been made during years audited by the NRC staff.

In LS-AA-110, Section 3, the licensee states that the Site Vice President has overall responsibility for the commitment tracking program. Licensing director/regulatory assurance managers designate the commitment tracking coordinators that are responsible for ensuring that commitments are properly captured in a commitment tracking database (CTD). The NRC staff reviewed procedures LS-TM-110-1003, Commitment Tracking Program for Use with Lotus Notes, and LS-AA-110-1001, Commitment Tracking Program T&RM for Use with Passport, that describe the licensees commitment tracking programs and establish the responsibilities, authorities, processes, and organizational interfaces for tracking and assuring compliance with the regulatory commitments.

As set forth in Section 2.1 above, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of this review of the licensees information, as well as information from other sources, the NRC staff found no reason to differ from the licensees reported status of the audited commitments. Therefore, the NRC staff surmises that the procedures used by the licensee to manage commitments are appropriate and effective.

3.0 CONCLUSION

The NRC staff concludes that, based on the above audit, (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 D. Distel Principal Contributor: F. E. Saba

AUDITED TMI-1 COMMITMENTS (2000 THROUGH 2005)

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-05-20102 May 03, 2005 MB6475 The proposed TMI-1 Updated Final Safety AR00180733-09 Complete MC7001 Analysis Report (UFSAR) updated wording will be implemented and posted against the TMI-1 UFSAR, and then incorporated into the subsequent UFSAR.

5928-05-20102 May 03, 2005 MB6475 Tubes with circumferential indications in the kinetic AR00180733-09 Complete MC7001 expansions required lengths will be removed from service upon detection - including circumferential Final ECR #02-01121, Revision indications that were detected during prior 1997 2, Pages 4 and 27 through 2003 outage examinations that remain in service in the kinetic expansions required lengths.

5928-05-20102 May 03, 2005 MB6475 Implement 100% examination scope of in-service AR00180733-09 Complete MC7001 kinetic expansions each refueling outage.

Final ECR #02-01121, Revision 2, Page 4 5928-05-20102 May 03, 2005 MB6475 Any tubes with flaws detected in the sleeves, or in AR00180733-09 Complete MC7001 the parent tube adjacent to the sleeve between the lower sleeve end and the parent tube kinetic Final ECR #02-01121, Revision expansion transition, will be plugged-on-detection. 2, Pages 23 and 42 5928-03-20148 August 06, MB9620 Licensed operator requalification training is in AR00166130-05 Complete RS-03-146 2003 progress and includes enhanced emergency core (5828-03-20148) cooling system (ECCS) throttling criteria. All licensed operators will complete classroom training.

5928-03-20148 August 06, MB9620 The plant will improve the containment closeout AR00166130-05 See AR00443432 RS-03-146 2003 inspection procedure to specifically address dirt, (5828-03-20148) dust, and small debris accumulation.

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-03-20148 August 06, MB9620 The plant will develop a specific procedure for AR00166130-07 Complete RS-03-146 2003 cleaning and inspecting the floor drains in (5828-03-20148) Procedure 661-OPS-4550-03, containment and will coordinate this work with the Revision 1 and Operating containment closeout procedure. Procedure Number 1101-05, Revision 4 5928-05-20223 August 18 MB9620 TMI-1 will revise the site emergency operating AR0282077-13 Complete 2005 procedures (EOP) to incorporate interim measures (5828-05-10223) to include initiating borated water storage tank (BWST) refill after switch-over to recirculation from the containment sump.

5928-05-20223 August 18 MB9620 TMI-1 will develop a written guideline that will AR0282077-14 Supplemented by September 26, 2005 cover re-injecting additional inventory from the (5828-05-10223) 2005 letter commitment BWST. This will include guidance for injecting more than one BWST volume from a refilled BWST or for injecting alternate water sources.

5928-05-20269 September 26, MB9620 In response to Bulletin 2003-01, TMI-1 will develop AR0282077-14 Complete 2005 a written guideline that will cover re-injecting (5828-05-10269) ER-TM-TSC-1018, Revision 0 additional inventory from the BWST. This will Note: The cited procedures is include guidance for injecting more than one annotated (marked with CM-1).

BWST volume from a refilled BWST or for injecting alternate water sources.

5928-05-20076 March 7, 2005 MC4724 If a strainer modification is required, TMI-1 will AR00282077-08 In progress: Scheduled RS-05-021 complete a preliminary debris loss analysis by AR00282077-09 completion date December 31, September 1, 2005. The final debris head loss AR00282077-10 2007 analysis will be completed as part of the strainer (5828-05-20076) Calculations completed modification in accordance with the NRC schedule Walkdown completed for GSI-191 resolution, and this analysis will include any additional impact found in the containment walkdown to be performed in November 2005.

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-05-20249 September 1, MC4724 The recirculation function for the ECCS and the AR00282077-19 In progress: Scheduled RS-03-116 2005 building spray (BS) system for TMI-1, will be in (5828-05-20249) completion date December 31, compliance with the regulatory requirements 2007 section of the subject generic letter under debris loading conditions by December 31, 2007.

5928-05-20249 September 1, MC4724 Overall completion of the downstream effects AR00282077-20 In progress when audited:

RS-03-116 2005 evaluation, including the fuel impact under the (5828-05-20249) Scheduled completion date current WCAP guidance, will occur by January 31, January 31, 2006 2006.

5928-05-20249 September 1, MC4724 The chemical effects evaluation (excluding vendor AR00282077-23 In progress when audited:

RS-03-116 2005 testing) will be completed by January 31, 2006 for (5828-05-20249) Scheduled completion date TMI-1. January 31, 2006 5928-05-20249 September 1, MC4724 TMI-1 will validate that adequate margin exists to AR00282077-26 In progress: Scheduled RS-03-116 2005 bound the impact of chemical effects once the (5828-05-20249) completion within 3 months after vendors tests results to quantify chemical debris vendor test results are published effect on head loss have been published.

AmerGen will update the TMI-1 NRC Project Manager with this scheduling information when the vendors have formulated their testing schedule.

5928-04-20162 October 20, MC4904 TMI-1 administrative controls will require: that AR00235958-5 Complete 2004 qualified personnel be designated; that required tools or equipment be identified and staged; and Procedure 1101-3, Sections that required guidance be provided to ensure that, 7.3.1.6.1 and 7.3.1.6.2 in the event of a fuel handling accident inside containment, containment equipment hatch closure is achieved within 45 minutes following an evacuation of the containment. Such prompt closure methods need not completely block the equipment hatch opening or be capable of resisting pressure.

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-04-20162 October 20, MC4904 TMI-1 will have procedures in place, which will AR00235958-5 Complete 2004 require operation of the Reactor Building Purge Exhaust System and bypassing of the Reactor Procedure 1101-3, Section Building Purge High Radiation isolation signal 7.3.1.6.3 whenever irradiated fuel movement is in progress OP-TM-823-408, Section 4.3 and containment integrity is not maintained. Procedure 1505-1, Datasheet 1, Operation of the Reactor Building Purge Exhaust Item F System is a contingency action, which will decrease doses even further by drawing any release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored.

5928-04-20162 October 20, MC4904 TMI-1 will have procedures in place which will AR00235958-5 Complete 2004 require the placement of continuously-operated particulate and radioiodine air sampling equipment Procedure 1101-3, Section inboard of the open containment equipment hatch 7.3.1.6.4 opening during fuel loading and refueling activities.

5928-05-20253 September 19, MC4904 Procedural controls will ensure that during the AR00235958-12 Complete 2005 movement of irradiated fuel the equipment hatch/missile shield area will be manned 24 Procedure 1101-3, Section hours/day, 7 days/week in support of the outage 7.3.1.6.2 unless the equipment hatch is closed and four bolts are installed.

5928-05-20253 September 19, MC4904 Complete permanent installation of steel plate to AR00235958-13 Complete 2005 the lower-most missile shield carriage area. The added steel plate will cover the area where grating A walkdown performed at 14:00 is currently installed. on October 25, 2005 found the installation of structural components met ECR 05-00382 requirements.

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-05-20253 September 19, MC4904 Prior to initial use of this Technical Specification, AR00235958-14 Complete 2005 TMI-1 will demonstrate that the 45-minute closure duration is achievable. Procedure MA-TM-156-900, Revision 0 and W/O C2010899 5928-05-20253 September 19, MC4904 TMI-1 procedures will include the following AR00235958-5 Complete 2005 requirements to ensure that General Design Criterion (GDC)-64 Ti R16 requirements will Requirements 1, 2 & 4 in continue to be met during the movement of Procedure 1101-3 irradiated fuel: Requirements 3 & 5 in

1) If the reactor building equipment hatch is OP-TM-823-408 removed (open), then place the purge system in Requirement 6 in Procedure operation and control the air flow at the hatch so 1505-1 that the prevailing continuous direction of air flow is into the reactor building.
2) If the condition, as described in Item 1 above, cannot be maintained, then fuel handling operations will be terminated until the reactor building equipment hatch is closed or purge is restored.
3) Whenever the purge system is operating, then ensure purge exhaust radiation monitor is operable or obtain periodic samples as currently specified in the Offsite Dose Calculation Manual.
4) Whenever the hatch is open, position a portable radiation monitor at the reactor building equipment hatch opening.
5) If the purge system is operated with the reactor building equipment hatch open, then bypass the reactor building purge exhaust high radiation interlock.
6) Prior to initiating irradiated fuel movement with the reactor building equipment.

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-02-20152 July 26, 2002 Establish a specification for contact area between AR 00110749-17 Complete (LER 2002-002- the upper spring washer and spring. The

00) specification will be established prior to the next Specification SP- 1101-12-020, refueling outage. Revision 8, Section 4.8.2 5928-02-20152 July 26, 2002 The rebuilt valve will be retested after one round AR 00110749-18 Complete (LER 2002-002- trip of normal shipping prior to use. Subject pressurizer safety code
00) satisfactorily tested on November 18, 2002.

5928-02-20062 March 15, Update drawings/vendor manual to reflect actual AR00090391-16 Complete (LER 2002-001- 2002 configuration. ECR 02-00504 was issued to

00) update drawings and revise vendor manual VM-TM-0172 5928-02-20062 March 15, Complete the installation of 480/460 VAC PIMS C2004- Complete (LER 2002-001- 2002 transformers for each inventor. 237, 299, 300,
00) 301, 302 (A2024085) 5928-02-20062 March 15, Verify the current procurement process will AR00090391-16 Complete (LER 2002-001- 2002 prevent this type of error (the original design of The current procurement process
00) power supplies to the vital power buses did not provides an improved technical meet certain design specifications.) review prior to order, access to the evaluated vendors list and improved quality assurance inspection.

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-01-20283 October 18, MC2336 The following commitment will be included as a This commitment was removed 2001 Category A commitment in the "Plan for the Long by Amendment No. 250, issued Range Planning Program for the Three Mile Island July 7, 2004.

Nuclear Station -Unit 1" as provided in TMI-1 Operating License Condition No. 2.c(9).

"A minimum Reactor Coolant System (RCS) flow rate of 105.5% of design flow (105.5% of 352,000 gpm) is specified to offset potential mixed core DNBR [departure from nucleate boiling ratio]

penalty for TMI-1 Cycle 14 and any subsequent cycle. This commitment expires when a mixed core penalty is no longer required or NRC-approved statistical core design methods are utilized which provide an alternative means of addressing transition core effects."

5928-01-20255 September 17, MB1051 TMI-1 administrative controls will require: that Complete 2001 qualified 1 R14 personnel be designated; that Procedure MA-TM-156-900, required tools or equipment be identified and Revision 0 and W/O C2010899 staged; and that required guidance be provided to ensure that containment closure is achieved within 45 minutes following the decision to isolate containment.

5928-01-20255 September 17, MB1051 The following commitment will be included as a Complete 2001 Category A 1 R14 commitment in the "Plan for the AmerGen Submittal Long Range Planning Program for the Three Mile 5928-01-20342, dated Island Nuclear Station -Unit 1" as provided in December 13, 2001 TMI-1 Operating License Condition No. 2.c(9),

prior to the start of the TMI-1 1R14 outage.

When handling irradiated fuel in the reactor building, a shiftly check and a daily verification (once per 24 hours1 days <br />0.143 weeks <br />0.0329 months <br />) shall be performed to confirm that the Fuel Transfer Canal water level is >23 feet above the reactor vessel flange (Technical Specification 3.8.11).

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-01-20108 April 11, 2001 MB1013 Subsequent to the TMI-1 14R refueling outage fuel ETTS Task Nos. Complete assembly Post Irradiation Examinations (PIE), 40816 and AmerGen submittal AmerGen will provide the NRC the results of the 40816-1 5928-02-20120, dated May 20, PIE data obtained for the M5 lead test rods. At 2002 (refueling outage 14) that time AmerGen will also provide to the NRC AmerGen submittal confirmation of the results of the TMI-1 Cycle 14 5928-05-20074, dated March 15, specific fuel rod design analysis for the M5 lead 2005 (refueling outage 15) test rods performed to determine acceptability for use in Cycle 14. If fuel rod behavior, as observed in the PIE, is not as expected or if analysis does not confirm fuel rod design criteria are met, then the M5 lead test rods will not be used in Cycle 14.

AmerGen will also provide the NRC the data obtained from PIE performed on the M5 lead test rods at the conclusion of TMI-1 operating Cycle 14.

5928-00-20280 September 8, Ensuring the adequacy of the acceptance criteria 5928 Complete 2000 for the daily operability surveillance check of the 20280.001 Commitment added to Technical makeup tank pressure instrument. Specification 4.1 bases (Page 4-2) 5928-04-20095 April 23, 2004 MC2760 AmerGen will develop and maintain contingency AR00220236-11 Complete plans for obtaining and analyzing highly AR00220236-13 Chemistry procedures N1830 radioactive samples from the RCS, containment N1831 sump, and containment atmosphere. The contingency plans will be contained in the TMI-1 chemistry procedures and implementation will be completed with the implementation of the license amendment. Establishment and maintenance of contingency plans is considered a regulatory commitment.

TMI-1 Submittal Submittal NRC Summary of Commitment TMI-1 Tracking Implementation Status Date TAC No. Number 5928-04-20095 April 23, 2004 MC2760 The capability for classifying fuel damage events AR00220236-08 Complete at the alert level threshold will be established for Capability was identified in the TMI-1 at radioactivity levels of 300 micro CVcc TMI-1 emergency plan.

dose equivalent iodine. This capability will be described in the TMI-1 emergency plan and emergency plan implementing procedures and implementation will be completed with the implementation of the license amendment. The capability for classifying fuel damage events is considered a regulatory commitment.

5928-04-20095 April 23, 2004 MC2760 AmerGen has verified that it has established the AR 00220236-15 Complete ability to assess radioactive iodines released to Capability was identified in the offsite environs. The capability for monitoring TMI-1 emergency plan.

iodines will be maintained within the TMI-1 emergency plan and emergency plan implementing procedures. Implementation of this commitment is complete. The capability to monitor radioactive iodines is considered a regulatory commitment.

5928-04-20065 October 20, MC2760 The as-found and as-left values will continue to be AR 00235945-03 To be completed by February 28, 2004 recorded and reviewed for consistency with the AR 00235945-06 2006 (not completed during the assumptions of the surveillance interval extension audit) analysis. The review will verify the test results meet acceptance criteria. Out-of-tolerance results will be evaluated to determine if they meet the requirements outlined in BAW-10167.

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