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| number = ML112210658
| number = ML112210658
| issue date = 09/07/2011
| issue date = 09/07/2011
| title = Audit of the Licensee Regulatory Commitment Management Program, Audit Performed July 19-20, 2011 (TAC Nos. ME6058 and ME6059)
| title = Audit of the Licensee Regulatory Commitment Management Program, Audit Performed July 19-20, 2011
| author name = Singal B
| author name = Singal B
| author affiliation = NRC/NRR/DORL/LPLIV
| author affiliation = NRC/NRR/DORL/LPLIV
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=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 September 7, 2011 Mr. Edward D. Halpin President and Chief Executive Officer!
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 September 7, 2011 Mr. Edward D. Halpin President and Chief Executive Officer!
Chief Nuclear Officer STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483 SUB.JECT:       SOUTH TEXAS PROJECT, UNITS 1 AND 2 - AUDIT OF THE LICENSEE'S REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NOS. ME6058 AND ME6059)
Chief Nuclear Officer STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483 SUB.JECT:
SOUTH TEXAS PROJECT, UNITS 1 AND 2 - AUDIT OF THE LICENSEE'S REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NOS. ME6058 AND ME6059)  


==Dear Mr. Halpin:==
==Dear Mr. Halpin:==
An audit of South Texas Project (STP), Units 1 and 2, commitment management program was performed at the plant site on July 19-20, 2011. In U.S. Nuclear Regulatory Commission (NRC)
An audit of South Texas Project (STP), Units 1 and 2, commitment management program was performed at the plant site on July 19-20, 2011. In U.S. Nuclear Regulatory Commission (NRC)
Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to NRC.
Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.
Based on the audit, the NRC staff concludes that STP Nuclear Operating Company (the licensee) has implemented NRC commitments on a timely basis, and the licensee has implemented an effective program for managing NRC commitment changes at STP, Units 1 and 2. The details of the results of the audit including the NRC staff's observations and recommendations are set forth in the enclosed audit report.
Based on the audit, the NRC staff concludes that STP Nuclear Operating Company (the licensee) has implemented NRC commitments on a timely basis, and the licensee has implemented an effective program for managing NRC commitment changes at STP, Units 1 and 2. The details of the results of the audit including the NRC staff's observations and recommendations are set forth in the enclosed audit report.  


E. Halpin                                   -2 If you have any questions, please contact me at (301) 415-3016 or via e-mail at Balwant.Singal@nrc.gov.
E. Halpin  
- 2 If you have any questions, please contact me at (301) 415-3016 or via e-mail at Balwant.Singal@nrc.gov.
Sincerely, b~t-4 t~I~~
Sincerely, b~t-4 t~I~~
Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499
Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499  


==Enclosure:==
==Enclosure:==
As stated cc w/encl: Distribution via Listserv


As stated cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499  
 
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499
 
==1.0    INTRODUCTION AND BACKGROUND==


==1.0 INTRODUCTION AND BACKGROUND==
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)
In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that commitments are implemented and that changes to the commitments are evaluated and, when appropriate, reported to NRC.
Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that commitments are implemented and that changes to the commitments are evaluated and, when appropriate, reported to NRC.
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NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.
NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.). The audit is to be performed once every 3 years.
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.). The audit is to be performed once every 3 years.
2.0     AUDIT PROCEDURE AND RESULTS An audit of South Texas Project (STP), Units 1 and 2, commitment management program was performed at the plant site on July 19-20, 2011. The audit reviewed commitments made by STP Nuclear Operating Company (STPNOC, the licensee) since the previous audit on August 19, Enclosure
2.0 AUDIT PROCEDURE AND RESULTS An audit of South Texas Project (STP), Units 1 and 2, commitment management program was performed at the plant site on July 19-20, 2011. The audit reviewed commitments made by STP Nuclear Operating Company (STPNOC, the licensee) since the previous audit on August 19, Enclosure  


                                                - 2 2008, which was documented in an audit report dated December 24, 2008 (ADAMS Accession No. ML083450162). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.
- 2 2008, which was documented in an audit report dated December 24, 2008 (ADAMS Accession No. ML083450162). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.
2.1     Verification of Licensee's Implementation of Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.
2.1 Verification of Licensee's Implementation of Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.
2.1.1   Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments, as defined above, made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) and licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample of commitments for verification. The identified list of commitments was forwarded to the licensee on July 6, 2011, with a request to locate documentation for the listed commitments ahead of the NRC staff audit. The licensee did not perform a self-assessment of the commitments identified for this audit.
2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments, as defined above, made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) and licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample of commitments for verification. The identified list of commitments was forwarded to the licensee on July 6, 2011, with a request to locate documentation for the listed commitments ahead of the NRC staff audit. The licensee did not perform a self-assessment of the commitments identified for this audit.
The audit excluded the following types of commitments that are internal to licensee processes:
The audit excluded the following types of commitments that are internal to licensee processes:
(1)     Commitments made on the licensee's own initiative among internal organizational components.
(1)
(2)     Commitments that pertain to milestones of licensing actions/activities (e.g.,
Commitments made on the licensee's own initiative among internal organizational components.
(2)
Commitments that pertain to milestones of licensing actions/activities (e.g.,
responding to an NRC request for additional information by a certain date).
responding 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.
Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.
(3)     Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
(3)
2.1.2   Audit Results The licensee has implemented Procedure OPGP05-ZN-0002, Revision 5, "Licensing Commitment Management and Administration," which identifies the methods and responsibilities for the maintenance of commitments and the Regulatory Commitments Management Program, which is used to ensure that the commitments are properly identified, tracked, closed out, revised/changed, or deleted. The licensee uses the program to track the
Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
2.1.2 Audit Results The licensee has implemented Procedure OPGP05-ZN-0002, Revision 5, "Licensing Commitment Management and Administration," which identifies the methods and responsibilities for the maintenance of commitments and the Regulatory Commitments Management Program, which is used to ensure that the commitments are properly identified, tracked, closed out, revised/changed, or deleted. The licensee uses the program to track the  


                                                -3 status and manage the closure of commitments at STP effectively. The licensee's Procedure OPGPOS-ZN-0002 is consistent with the guidance provided by NEI 99-04.
- 3 status and manage the closure of commitments at STP effectively. The licensee's Procedure OPGPOS-ZN-0002 is consistent with the guidance provided by NEI 99-04.
As discussed above, the licensee's program provides acceptable tools and guidance for the licensee to capture the NRC guidance on commitment management programs. The licensee enters the commitments made to the NRC into the program. The commitments are entered as Condition Records (CRs) in the Corrective Action Program Database (CAPD). The field for "Action Type" in the CR further identifies the CR as a regulatory commitment for the purposes of tracking. The status of the commitments, implementation dates, target implementation document information associated with each specific commitment, and comments are captured in the program.
As discussed above, the licensee's program provides acceptable tools and guidance for the licensee to capture the NRC guidance on commitment management programs. The licensee enters the commitments made to the NRC into the program. The commitments are entered as Condition Records (CRs) in the Corrective Action Program Database (CAPD). The field for "Action Type" in the CR further identifies the CR as a regulatory commitment for the purposes of tracking. The status of the commitments, implementation dates, target implementation document information associated with each specific commitment, and comments are captured in the program.
The documents furnished by the licensee during the audit included summary sheets from the CAPD providing the status of the CR/commitments and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation incorporating the commitments). The NRC staff reviewed the documents and summarized the results of the review of the selected commitments in the attached table to this audit report.
The documents furnished by the licensee during the audit included summary sheets from the CAPD providing the status of the CR/commitments and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation incorporating the commitments). The NRC staff reviewed the documents and summarized the results of the review of the selected commitments in the attached table to this audit report.
The NRC staff's audit was intended to confirm that the licensee has documented its implementation of commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.
The NRC staff's audit was intended to confirm that the licensee has documented its implementation of commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.
The NRC staffs audit of the licensee's commitment management program for STP, Units 1 and 2, identified the following deficiencies (refer to the attached table to this report for the CR number and description of each individual CR):
The NRC staffs audit of the licensee's commitment management program for STP, Units 1 and 2, identified the following deficiencies (refer to the attached table to this report for the CR number and description of each individual CR):
* Condition Record 08-9676-2S: The CR was not coded as a regulatory commitment as required by the licensee's Procedure OPGPOS-ZN-0002, Revision S. At the conclusion of this audit, the licensee was in the process of correcting the error.
Condition Record 08-9676-2S: The CR was not coded as a regulatory commitment as required by the licensee's Procedure OPGPOS-ZN-0002, Revision S. At the conclusion of this audit, the licensee was in the process of correcting the error.
* Condition Record 11-S788-2: The commitment was entered into the CAPD as a regulatory commitment, but incorrectly coded as not docketed. At the conclusion of this audit, the licensee was in the process of correcting the error.
Condition Record 11-S788-2: The commitment was entered into the CAPD as a regulatory commitment, but incorrectly coded as not docketed. At the conclusion of this audit, the licensee was in the process of correcting the error.
The results of the review indicated that the commitments were implemented and/or incorporated satisfactorily and the licensee has an effective commitment management program, with the exception of the deficiencies detailed above. The deficiencies identified above had no safety significance and the licensee was in the process of correcting the deficiencies.
The results of the review indicated that the commitments were implemented and/or incorporated satisfactorily and the licensee has an effective commitment management program, with the exception of the deficiencies detailed above. The deficiencies identified above had no safety significance and the licensee was in the process of correcting the deficiencies.
Also, the target document (e.g., procedures) listed the commitments contained in the document in a section entitled "References." To ensure that commitments are not removed or changed in future revisions to the target documents, the target documents clearly identified the areas incorporating specific commitments by reference to the CR number.
Also, the target document (e.g., procedures) listed the commitments contained in the document in a section entitled "References." To ensure that commitments are not removed or changed in future revisions to the target documents, the target documents clearly identified the areas incorporating specific commitments by reference to the CR number.  


                                                -4 Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitment management program adequately and consistent with NEI 99-04, except for the deficiencies identified during the audit.
-4 Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitment management program adequately and consistent with NEI 99-04, except for the deficiencies identified during the audit.
2.2     Verification of the Licensee's Program for Managing NRC Commitment Changes 2.2.1   Audit Scope The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at STP, Units 1 and 2, is contained in Procedure OPGP05-ZN-0002, Revision 5. The primary focus of the audit was to ensure that the commitments are implemented without a change and if a change is made, it is in accordance with the approved plant procedures and with the approval of the plant's management. The audit also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.
2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes 2.2.1 Audit Scope The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at STP, Units 1 and 2, is contained in Procedure OPGP05-ZN-0002, Revision 5. The primary focus of the audit was to ensure that the commitments are implemented without a change and if a change is made, it is in accordance with the approved plant procedures and with the approval of the plant's management. The audit also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.
2.2.2   Audit Results No other commitment changes were identified during the audit, except for changes to the implementation dates for some of the commitments. In all such cases, the licensee generated a Commitment Evaluation Form in accordance with the plant procedures and the review by NRC concluded that the justifications provided by the licensee were adequate.
2.2.2 Audit Results No other commitment changes were identified during the audit, except for changes to the implementation dates for some of the commitments. In all such cases, the licensee generated a Commitment Evaluation Form in accordance with the plant procedures and the review by NRC concluded that the justifications provided by the licensee were adequate.
Based on its review, the NRC staff concludes that the changes to regulatory commitments are being reported to NRC consistent with the NRC guidance.
Based on its review, the NRC staff concludes that the changes to regulatory commitments are being reported to NRC consistent with the NRC guidance.
3.0     OBSERVATIONS AND RECOMMENDATIONS Deficiencies in the commitment management program identified during the NRC audit are identified in Section 2.1.2 of this report. These deficiencies had no safety significance and at the conclusion of the audit, the licensee was in the process of correcting the deficiencies.
3.0 OBSERVATIONS AND RECOMMENDATIONS Deficiencies in the commitment management program identified during the NRC audit are identified in Section 2.1.2 of this report. These deficiencies had no safety significance and at the conclusion of the audit, the licensee was in the process of correcting the deficiencies.
However, based on the NRC staff's review, the staff would like to make the following recommendation:
However, based on the NRC staff's review, the staff would like to make the following recommendation:
Presently, the CR containing the specific regulatory commitment is identified in the reference section and the body of the target document being revised without any specific markings for the area of change. This makes it difficult to locate the sections of the target document containing regulatory commitments. The licensee agreed to identify the regulatory commitments in the margin area of the target documents (e.g. procedures) for easy traceability and to eliminate the potential for unintentional change to the commitment in future.
Presently, the CR containing the specific regulatory commitment is identified in the reference section and the body of the target document being revised without any specific markings for the area of change. This makes it difficult to locate the sections of the target document containing regulatory commitments. The licensee agreed to identify the regulatory commitments in the margin area of the target documents (e.g. procedures) for easy traceability and to eliminate the potential for unintentional change to the commitment in future.  
 
                                                -5


==4.0    CONCLUSION==
- 5


==4.0 CONCLUSION==
Based on the results of the audit, the NRC staff concludes that the licensee has implemented the commitment management program effectively, and implemented commitment changes appropriately consistent with NEI 99-04. The licensee was in the process of taking action to correct the deficiencies identified during the audit. The deficiencies identified during the audit did not have any safety significance.
Based on the results of the audit, the NRC staff concludes that the licensee has implemented the commitment management program effectively, and implemented commitment changes appropriately consistent with NEI 99-04. The licensee was in the process of taking action to correct the deficiencies identified during the audit. The deficiencies identified during the audit did not have any safety significance.
5.0     LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Marilyn Kistler Wayne Harrison Principal Contributors: B. Singal R. Grover Date:   September 7, 2011
5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Marilyn Kistler Wayne Harrison Principal Contributors: B. Singal R. Grover Date: September 7, 2011  


==Attachment:==
==Attachment:==
Audit Summary Table


Audit Summary Table
Summary of Audit of Regulatory Commitments and Results of Audit Performed on July 19-20, 2011 STP Nuclear Operating Company South Texas Project, Units 1 and 2 Docket Nos. 50-498 and 50-499 Letter No.
 
Subject Condition Record No.
Summary of Audit of Regulatory Commitments and Results of Audit Performed on July 19-20, 2011 STP Nuclear Operating Company South Texas Project, Units 1 and 2 Docket Nos. 50-498 and 50-499
NOC-AE-08002328 6/26/2008 (ADAMS Accession No. ML081890190)
                                      -------                        -
Request to Extend Implementation Date for Emergency Core Cooling System Sump Design Basis CR 02-5326-111 CR 02-5326-112 CR 02-5326-113 Implementation Status Description of Commitment Closed on 811312008.
Condition Letter No.     Subject           Record No.                     Description of Commitment                    Implementation Status
or n ore debris load combinations that can be r itigated by the South Texas Project The test will be structured to determine one The commitment was entered into the (STP) sump strainers. (Complete by test Corrective Action Program Database corr pletion date, currently 7/30/2008).
------
(CAPO) as a regulatory commitment.
NOC-AE-08002328     Request to         CR 02-5326-111         The test will be structured to determine one    Closed on 811312008.
The results of the test specified in the Condition Record (CR) were acceptable and, as a result, the CR was closed.  
6/26/2008 (ADAMS    Extend                                    or n ore debris load combinations that can Accession No.      Implementation                            be r itigated by the South Texas Project       The commitment was entered into the ML081890190)        Date for                                  (STP) sump strainers. (Complete by test         Corrective Action Program Database Emergency Core                            corr pletion date, currently 7/30/2008).       (CAPO) as a regulatory commitment.
--------------------------+-1  
Cooling System Sump Design                                                                                The results of the test specified in the Basis                                                                                      Condition Record (CR) were acceptable and, as a result, the CR was closed.
--------------------~
                                                                        --------------------------+-1                 --------------------~
STF will consider contingencies listed in the Closed on 8/13/2008.
CR 02-5326-112          STF will consider contingencies listed in the Closed on 8/13/2008.
cov r letter should strainer testing not den onstrate satisfactory performance.
cov r letter should strainer testing not den onstrate satisfactory performance.         The commitment was entered into the (Complete by test completion date, currently CAPO as a regulatory commitment.
The commitment was entered into the (Complete by test completion date, currently CAPO as a regulatory commitment.
7/3( 12008).
7/3( 12008).
The results of the strainer test specified in the CR were determined to be acceptable and the CR was closed.
The results of the strainer test specified in the CR were determined to be acceptable and the CR was closed.  
                                    ....    ---------          ------      --------------11-------'-----**
--------------11-------'-----**
CR 02-5326-113          Tes ng plan and contingency options             Open.
Tes ng plan and contingency options Open.
pr01 de assurance that the Generic Safety ISSl e (GSI)-191 and Generic Letter (GL)       The commitment was entered into the 200 -02 issues will be resolved for STP,       CAPO as a regulatory commitment.
pr01 de assurance that the Generic Safety ISSl e (GSI)-191 and Generic Letter (GL)
The commitment was entered into the 200 -02 issues will be resolved for STP, CAPO as a regulatory commitment.
Unil s 1 and 2, by 12/31/2009.
Unil s 1 and 2, by 12/31/2009.
The completion date was changed to 4/1/2012. Commitment Evaluation Form documenting the justification for the extension was reviewed and the I ch<3~ge was found acceptable.
The completion date was changed to 4/1/2012. Commitment Evaluation Form documenting the justification for the extension was reviewed and the I ch<3~ge was found acceptable.  
                                    -_. .
-----------------~
                                                                            -----------------~
Attachment  
Attachment


                                                                        - 2
- 2 Subject Letter No.
--------                                                             ------
NOC-AE-08002372 12/11/2008 (ADAMS Accession No. ML083520326)
Condition Letter No.            Subject        Record No.           Description of Commitment                  Implementation Status
NOC-AE-09002389 31312009 (ADAMS Accession No. ML090690687)
                    . -                                                                                         ------
NOC-AE-09002477 10/14/2009 (ADAMS Accession No. ML092930172)
NOC-AE-08002372          Response  to    CR 02-5326-120 When a final Safety Evaluation for           Open.
Response to Generic Letter 2004-02 License Amendment Request for Adoption of TSTF-511.
12/11/2008              Generic Letter                  WCAP-16793. "Long Term Cooling" is (ADAMS                  2004-02                          issued, STP will review it for impact on its The commitment is identified as a Accession No.                                            long-term cooling methodology.              regulatory commitment in the CAPD.
Revision 0, "Eliminate Working Hour Restrictions From TS 5.2.2 To Support Compliance With 10 CFR Part 26."
ML083520326)                                              Expected completion date: 6/30/2009.
Revised Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue Condition Record No.
CR 02-5326-120 09-1587-2 09-10811-4 Description of Commitment When a final Safety Evaluation for WCAP-16793. "Long Term Cooling" is issued, STP will review it for impact on its long-term cooling methodology.
Expected completion date: 6/30/2009.
Removal of the plant-specific Technical Specification (TS) requirements will be performed concurrently with the implementation of the 10 CFR Part 26.
Subpart I requirements. This commitment will be completed no later than the implementation deadline of 10/1/2009.
When the Fitness for Duty Rule for Managing Fatigue is changed and an exemption from the requirements of 10 CFR 26.205(c) and (d) for meeting work hour controls during declarations of severe weather conditions involving tropical storm or hurricane force winds is no longer needed, STP Nuclear Operating Company (STPNOC) will submit a letter to the NRC stating that the exemption is no longer needed by 12/3112011.
Implementation Status Open.
The commitment is identified as a regulatory commitment in the CAPD.
The commitment completion date has been changed to 12/15/2011. The Commitment Evaluation Form justifying the change in completion date was reviewed and the change was found acceptable.
The commitment completion date has been changed to 12/15/2011. The Commitment Evaluation Form justifying the change in completion date was reviewed and the change was found acceptable.
                  -------
Closed on 10/1/2009.
NOC-AE-09002389          License              09-1587-2  Removal of the plant-specific Technical      Closed on 10/1/2009.
The commitment was identified as a regulatory commitment in the CAPD.
31312009 (ADAMS          Amendment                        Specification (TS) requirements will be Accession No.            Request for                      performed concurrently with the              The commitment was identified as a ML090690687)            Adoption of                      implementation of the 10 CFR Part 26.        regulatory commitment in the CAPD.
The commitment is fully met as reflected in TS Amendment Nos. 192 for STP, Unit 1, and 180 for STP.
TSTF-511.                        Subpart I requirements. This commitment Revision 0,                      will be completed no later than the          The commitment is fully met as "Eliminate                      implementation deadline of 10/1/2009.        reflected in TS Amendment Nos. 192 Working Hour                                                                  for STP, Unit 1, and 180 for STP.
Unit 2.
Restrictions From                                                            Unit 2.
Open.
TS 5.2.2 To Support Compliance With 10 CFR Part 26."
The commitment is identified as a regulatory commitment in the CAPD.
NOC-AE-09002477          Revised Request    09-10811-4  When the Fitness for Duty Rule for          Open.
The licensee has already received approval for the exemption. However, the licensee needs to issue a letter to the NRC by 12/31/2011. to confirm that the exemption is no longer required.  
10/14/2009              for Exemption                    Managing Fatigue is changed and an (ADAMS                  from Certain                    exemption from the requirements of 10 CFR    The commitment is identified as a Accession No.            Requirements of                  26.205(c) and (d) for meeting work hour      regulatory commitment in the CAPD.
ML092930172)            the Fitness for                  controls during declarations of severe Duty Rule for                    weather conditions involving tropical storm  The licensee has already received Managing                        or hurricane force winds is no longer        approval for the exemption. However, Fatigue                          needed, STP Nuclear Operating Company        the licensee needs to issue a letter to (STPNOC) will submit a letter to the NRC    the NRC by 12/31/2011. to confirm that stating that the exemption is no longer      the exemption is no longer required.
needed by 12/3112011.


                                                                -3 r~~
-3 r~~
Condition Letter No.       Subject     Record No.               Description of Commitment                   Implementation Status       .
Letter No.
NOC-AE-09002480 License           09-10761-6       STPNOC will have implemented the             Closed on 7/26/2010.
Subject Condition Record No.
11/19/2009      Amendment                          requirements of 10 CFR 73.54. 60 months (ADAMS          Request for                        after NRC approval of the STPNOC Cyber       The commitment was entered into the Accession No. Approval of                        Security Plan.                              CAPO as a regulatory commitment.
Description of Commitment Implementation Status NOC-AE-09002480 11/19/2009 (ADAMS Accession No. ML093280720)
ML093280720)    Cyber Security Plan                                                                            The license amendment request was withdrawn by the licensee by letter dated 7/27/2010 (ADAMS Accession No. ML102150159). and the commitment is no longer valid.
License Amendment Request for Approval of Cyber Security Plan 09-10761-6 STPNOC will have implemented the requirements of 10 CFR 73.54. 60 months after NRC approval of the STPNOC Cyber Security Plan.
NOC-AE-10002558 Licensee         09-10811-9       The conditions necessary to sequester site   Closed on 8/31/2010.
Closed on 7/26/2010.
5/10/2010 (ADAMS Commitment                          personnel that are consistent with the Accession No. Regarding a                        conditions specified in the exemption       The commitment is identified as a ML101340116)    Request for                        request (NOC-AE-09002477. ADAMS             regulatory commitment in the CAPO.
The commitment was entered into the CAPO as a regulatory commitment.
Exemption from                    Accession No. ML092930172). on approval Certain                            of the request for exemption will be       Procedure OPGP03-ZV-0002.
The license amendment request was withdrawn by the licensee by letter dated 7/27/2010 (ADAMS Accession No. ML102150159). and the commitment is no longer valid.
Requirements of                    maintained in the site procedures.          Revision 5 incorporates the the Fitness for Duty Rule for    09-10811-9       Provisions for ensuring that personnel who commitment.
NOC-AE-10002558 5/10/2010 (ADAMS Accession No. ML101340116)
                                                                                                  ----
Licensee Commitment Regarding a Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue 09-10811-9 The conditions necessary to sequester site personnel that are consistent with the conditions specified in the exemption request (NOC-AE-09002477. ADAMS Accession No. ML092930172). on approval of the request for exemption will be maintained in the site procedures.
Closed on 8/31/2010.
The commitment is identified as a regulatory commitment in the CAPO.
Procedure OPGP03-ZV-0002.
Revision 5 incorporates the commitment.
09-10811-9 Provisions for ensuring that personnel who are not performing duties are provided an opportunity as well as accommodations for restorative rest on approval of the request for exemption will be maintained in the site procedures.
Closed on 8/3112010.
Closed on 8/3112010.
I Managing                          are not performing duties are provided an Fatigue                            opportunity as well as accommodations for    The commitment is identified as a restorative rest on approval of the request  regulatory commitment in the CAPO.
The commitment is identified as a regulatory commitment in the CAPO.
for exemption will be maintained in the site procedures.                                  Procedure OPGP03-ZV-0002, Revision 5 incorporates the
Procedure OPGP03-ZV-0002, I
                                  -------
Revision 5 incorporates the commitment.
commitment.                         I 09-10811-9       The condition for departure from the         Closed on 8/31/2010.
09-10811-9 The condition for departure from the exemption is based on the Emergency Operations Facility Director's determination that adequate staffing is available to meet the requirements of 10 CFR 26.205(c) and (d) on approval of the request for exemption will be maintained in the site procedures.
exemption is based on the Emergency Operations Facility Director's determination The commitment is identified as a that adequate staffing is available to meet regulatory commitment in the CAPO.
Closed on 8/31/2010.
the requirements of 10 CFR 26.205(c) and (d) on approval of the request for exemption Procedure OPGP03-ZV-0002. Revision
The commitment is identified as a regulatory commitment in the CAPO.
                                              ~---~
Procedure OPGP03-ZV-0002. Revision 5 incorporates the commitment.
will be maintained in the site procedures.
~---~ --~~
                                                    --~~
I
5 incorporates the commitment.


                                                            -4
-4 Condition Letter No.
                                                                                                ------------------
Subject Record No.
Condition Letter No.         Subject     Record No.           Description of Commitment                     Implementation Status NOC-AE-10002594 Request for       08-9676-25 If a containment spray (CS), low head safety Closed on 10/27/2010.
Description of Commitment Implementation Status NOC-AE-10002594 Request for 08-9676-25 If a containment spray (CS), low head safety Closed on 10/27/2010.
9/20/2010 (ADAMS Relief from                   injection (LHSI), or high head safety Accession No. ASME Section XI               injection (HHSI) pump is disassembled         Verified procedure OPGP03-ZE-0027 ML102700175)   Code                         during the third inspection interval, STPNOC (Revision 29), Addendum 6, Section Requirements for             will perform the Code-required surface       5.0. The commitment was entered into Pump Casing                   examination of the pump casing welds         the CAPO as CR 8-9676-25, but was Inservice                     within the pump pit by 12/12/2010             not coded as a regulatory commitment.
9/20/2010 (ADAMS Relief from injection (LHSI), or high head safety Accession No.
Inspection                   (incorporation into procedure).               The licensee was in the process of Examination                                                                 correcting the error.
ASME Section XI injection (HHSI) pump is disassembled Verified procedure OPGP03-ZE-0027 ML102700175)
NOC-AE-10002623 Revision to       10-24696-03 Lead Test Assembly (LTA) measured data       Open.
Code during the third inspection interval, STPNOC (Revision 29), Addendum 6, Section Requirements for will perform the Code-required surface 5.0. The commitment was entered into Pump Casing examination of the pump casing welds the CAPO as CR 8-9676-25, but was Inservice within the pump pit by 12/12/2010 not coded as a regulatory commitment.
12/21/2010       Technical                     and favorable results from visual (ADAMS           Specifications               examinations of once, twice, and thrice       Commitment entered into CAPO as a Accession No. 5.3.1 and 6.9.1.6             burned LT As confirm, for three cycles of     regulatory commitment.
Inspection (incorporation into procedure).
ML103630408)   to Allow Fuel                 operation, that the current fuel performance Assemblies with               models are applicable for Optimized           The commitment to be incorporated Optimized                     ZIRLO' clad fuel rods. Westinghouse will     prior to loading fuel rods with ZIRLO'                       continue to provide additional data from the Optimized ZIRLO' cladding.
The licensee was in the process of Examination correcting the error.
Cladding                     Optimized ZIRLO' LTA programs to the NRC as it becomes available.
NOC-AE-10002623 Revision to 10-24696-03 Lead Test Assembly (LTA) measured data Open.
It is stated in the commitment that confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLO' fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. It further states that until the commitment is complete, STPNOC will confirm that, as higher burnupslfluences are achieved for Optimized ZIRLO' clad fuel rods, the requirements of this condition are met as it applies to STP, Units 1 and 2.
12/21/2010 Technical and favorable results from visual (ADAMS Specifications examinations of once, twice, and thrice Commitment entered into CAPO as a Accession No.
5.3.1 and 6.9.1.6 burned L T As confirm, for three cycles of regulatory commitment.
ML103630408) to Allow Fuel operation, that the current fuel performance Assemblies with models are applicable for Optimized The commitment to be incorporated Optimized ZIRLO' clad fuel rods. Westinghouse will prior to loading fuel rods with ZIRLO' continue to provide additional data from the Optimized ZIRLO' cladding.
Cladding Optimized ZIRLO' L TA programs to the NRC as it becomes available.
It is stated in the commitment that confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLO' fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. It further states that until the commitment is complete, STPNOC will confirm that, as higher burnupslfluences are achieved for Optimized ZIRLO' clad fuel rods, the requirements of this condition are met as it applies to STP, Units 1 and 2.  


                                                              -5
- 5 Condition Letter No.
                    ---------------
Description of Commitment Implementation Status Subject Record No.
Condition Letter No.           Subject      Record No.            Description of Commitment                   Implementation Status
Data from three cycles of operation have Open.
                ---------------------
Technical NOC-AE-10002623 Revision to 10-24696-04 been evaluated and the fuel rod creep (continued) models from fuel rod design codes have Verified the CAPO. Commitment Specifications been used to predict growth and creep entered into CAPO as a regulatory to Allow Fuel 5.3.1 and 6.9.1.6 performance of the samples. This commitment Assemblies with information was provided to the NRC in the Optimized The commitment to be incorporated ZIRLO' most recent informational letter (V L TR-prior to loading fuel rods with Cladding NRC-10-43) dated 7/26/2010. Confirmation Optimized ZIRLO' cladding.
NOC-AE-10002623 Revision to           10-24696-04 Data from three cycles of operation have      Open.
Technical                        been evaluated and the fuel rod creep (continued)     Specifications                    models from fuel rod design codes have       Verified the CAPO. Commitment 5.3.1 and 6.9.1.6                been used to predict growth and creep         entered into CAPO as a regulatory to Allow Fuel                     performance of the samples. This             commitment Assemblies with                   information was provided to the NRC in the Optimized                         most recent informational letter (V LTR-     The commitment to be incorporated ZIRLO'                            NRC-10-43) dated 7/26/2010. Confirmation     prior to loading fuel rods with Cladding                          of the approved models' applicability up      Optimized ZIRLO' cladding.
through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. Until the commitment is complete, STPNOC will confirm that the requirements of this condition are met as it applies to STP, Units 1 and 2.
through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. Until the commitment is complete, STPNOC will confirm that the requirements of this condition are met as it applies to STP, Units 1 and 2.
10-24696-05 The relative differences in unirradiated     Open.
10-24696-05 of the approved models' applicability up The relative differences in unirradiated Open.
strength (YS and UTS) between Optimized ZIRLO' and standard ZIRLO' in cladding       Verified the CAPO. Commitment and structural analyses will be accounted for entered into CAPO as a regulatory until irradiation data for Optimized ZIRLO'   commitment.
strength (YS and UTS) between Optimized ZIRLO' and standard ZIRLO' in cladding Verified the CAPO. Commitment and structural analyses will be accounted for entered into CAPO as a regulatory until irradiation data for Optimized ZIRLO' commitment.
is accepted by the NRC staff. Analysis of Optimized ZIRLO' clad fuel rods will use     The commitment to be incorporated the yield strength and ultimate tensile       prior to loading fuel rods with strength as modified per Conditions a.a.i,   Optimized ZIRLO' cladding.
is accepted by the NRC staff. Analysis of Optimized ZIRLO' clad fuel rods will use The commitment to be incorporated the yield strength and ultimate tensile prior to loading fuel rods with strength as modified per Conditions a.a.i, Optimized ZIRLO' cladding.
a.a.H, and a.a.iii until such time that irradiation data for Optimized ZIRLO' strengths are collected and provided to the NRC.
a.a.H, and a.a.iii until such time that irradiation data for Optimized ZIRLO' strengths are collected and provided to the NRC.
Until the values are accepted by the NRC, STPNOC will confirm that the requirements of this condition are met as it applies to STP, Units 1 and 2.
Until the values are accepted by the NRC, STPNOC will confirm that the requirements of this condition are met as it applies to STP, Units 1 and 2.  


                                                              -6
-6 Letter No.
                                                                                                                                    -------------
Subject Condition Record No.
Condition Letter No.       Subject       Record No.           Description of Commitment                       Implementation Status NOC-AE-11002661   Revision to the   11-5788-2* STPNOC will revise its License Amendment         Closed on 4/28/2011.
Description of Commitment Implementation Status NOC-AE-11002661 4/412011 (ADAMS Accession No. ML111090384) and NOC-AE-11002688 6/28/2011 (ADAMS Accession No. ML11182A911)
4/412011 (ADAMS  Facility Operating            Request for approval of the Cyber Security Accession No. License and                  Plan (submitted to the NRC on 7/27/2010;         The commitment was entered into the ML111090384) and Request for                  ADAMS Accession No. ML102150159) by             CAPD as a regulatory commitment, but NOC-AE-11002688  Review and                    inserting the following words into section 2.1   incorrectly coded as not docketed.
Revision to the Facility Operating License and Request for Review and Approval of the Cyber Security Plan 11-5788-2*
6/28/2011 (ADAMS  Approval of the              of the Cyber Security Plan (CSP):
STPNOC will revise its License Amendment Request for approval of the Cyber Security Plan (submitted to the NRC on 7/27/2010; ADAMS Accession No. ML102150159) by inserting the following words into section 2.1 of the Cyber Security Plan (CSP):  
Accession No. Cyber Security                                                                  Verified STPNOC letter dated ML11182A911)      Plan                          "Within the scope of NRC's cyber security         4/28/2011 (ADAMS Accession No.
"Within the scope of NRC's cyber security rule at Title 10 of the Code ofFederal Regulations (10 CFR) 73.54, systems or equipment that perform important to safety functions include structures, systems, and components (SSCs) in the balance of plant (BOP) that could directly or indirectly affect reactivity at a nuclear power plant and could result in an unplanned reactor shutdown or transient. Additionally, these SSCs are under the licensee's control and include electrical distribution equipment out to the first inter-tie with the offsite distribution system." "No later than December 31, 2012."
rule at Title 10 of the Code of Federal          ML11123A217) incorporating the Regulations (10 CFR) 73.54, systems or           commitment.
Closed on 4/28/2011.
equipment that perform important to safety functions include structures, systems, and components (SSCs) in the balance of plant (BOP) that could directly or indirectly affect reactivity at a nuclear power plant and could result in an unplanned reactor shutdown or transient. Additionally, these SSCs are under the licensee's control and include electrical distribution equipment out to the first inter-tie with the offsite distribution system." "No later than December 31, 2012."
The commitment was entered into the CAPD as a regulatory commitment, but incorrectly coded as not docketed.
11-5788-3* Establish Cyber Security Assessment Team Closed on 7/11/2011.
Verified STPNOC letter dated 4/28/2011 (ADAMS Accession No. ML11123A217) incorporating the commitment.
(CSAT) as described in Section 3.1.2 "Cyber Security Assessment Team" of the CSP no The commitment was entered into the later than 12/31/2012.                           CAPD as a regulatory commitment.
11-5788-3*
Establish Cyber Security Assessment Team (CSAT) as described in Section 3.1.2 "Cyber Security Assessment Team" of the CSP no later than 12/31/2012.
Closed on 7/11/2011.
The commitment was entered into the CAPD as a regulatory commitment.
Verified that STPNOC has already established the cyber security team roster.
Verified that STPNOC has already established the cyber security team roster.
11-5788-4* Identify Critical Systems (CSs) and Critical     Closed on 7/1112011.
11-5788-4*
Digital Assets (CDAs) as described in Section 3.1.3 "Identification of Critical Digital The commitment was entered into the Assets" of the CSP no later than                 CAPD as a regulatory commitment.
Identify Critical Systems (CSs) and Critical Digital Assets (CDAs) as described in Section 3.1.3 "Identification of Critical Digital Assets" of the CSP no later than 12/31/2012.
12/31/2012.                                      Verified STPNOC has already identified CSs and CDAs as described in Section 3.1.3 of the CSP. However, the detailed description of the CSs and CDAs was not reviewed, being a security-related document.
Closed on 7/1112011.
The commitment was entered into the CAPD as a regulatory commitment.
Verified STPNOC has already identified CSs and CDAs as described in Section 3.1.3 of the CSP. However, the detailed description of the CSs and CDAs was not reviewed, being a security-related document.  


                                                                      -7 Condition Letter No.           Subject             Record No.
- 7 Condition Description of Commitment Implementation Status Letter No.
                                              ---
Subject Record No.
Description of Commitment                        Implementation Status NOC-AE-11002661      Revision to the          11-5788-5* Implement Installation of a deterministic         Open.
11-5788-5*
and                 Facility Operating                 one-way device between lower level devices NOC-AE-11002688       License and                        (level 2 and 3) and a firewall between higher     The commitment was entered into the (continued)          Request for                         level devices (level 3 and 4) as described in     CAPD as a regulatory commitment in Review and                          Section 4.3, "Defense-In-Depth Protective         accordance with Revision 5 of Approval of the                     Strategies" of the CSP.                          Procedure OPGP03-ZV-0002.
Implement Installation of a deterministic Open.
Cyber Security Plan                               Lower security level devices ([level 0, 1, 2 devices]) that bypass the deterministic device and connect to level 3 or 4 will be modified to prevent the digital connectivity to the higher level or will be modified to meet cyber security requirements commensurate with the level [3 or 4] devices to which they connect.
and NOC-AE-11002661 Revision to the Facility Operating one-way device between lower level devices NOC-AE-11002688 The commitment was entered into the (continued)
The design modifications that are not finished by the completion date will be documented in the site configuration management andlor change control program to assure completion of the design modification as soon as possible, but no later than the final implementation date
(level 2 and 3) and a firewall between higher License and CAPD as a regulatory commitment in Review and Request for level devices (level 3 and 4) as described in Section 4.3, "Defense-In-Depth Protective accordance with Revision 5 of Approval of the Procedure OPGP03-ZV-0002.
                                        -----
Cyber Security Plan Strategies" of the CSP.
(12/31/2012).
Lower security level devices ([level 0, 1, 2 devices]) that bypass the deterministic device and connect to level 3 or 4 will be modified to prevent the digital connectivity to the higher level or will be modified to meet cyber security requirements commensurate with the level [3 or 4] devices to which they connect.
11-5788-6* The security control "Access Control For         Open.
The design modifications that are not finished by the completion date will be documented in the site configuration management andlor change control program to assure completion of the design modification as soon as possible, but no later than the final implementation date (12/31/2012).
Portable And Mobile Devices" described in Appendix D 1.19 of NEI 08-09, Revision 6,         The commitment was entered into the will be implemented no later than                 CAPD as a regulatory commitment in 12/31/2012.                                      accordance with Revision 5 of Procedure OPGP03-ZV-0002.
The security control "Access Control For Open.
                                                                                                              ------
Portable And Mobile Devices" described in Appendix D 1.19 of NEI 08-09, Revision 6, 11-5788-6*
                                        ---
The commitment was entered into the will be implemented no later than CAPD as a regulatory commitment in accordance with Revision 5 of Procedure OPGP03-ZV-0002.
11-5788-7* Implement observation and identification of      Open.
11-5788-7*
obvious cyber related tampering to existing insider mitigation rounds by incorporating       The commitment was entered into the the appropriate elements in Appendix E,           CAPD as a regulatory commitment in Section 4.3 "Personnel Performing                 accordance with Revision 5 of Maintenance and Testing Activities" no later     Procedure OPGP03-ZV-0002.
12/31/2012.
      ---_.-    --_.                              ---_.
Open.
than 12/31/2012.               ---_.-    ---
obvious cyber related tampering to existing insider mitigation rounds by incorporating Implement observation and identification of The commitment was entered into the the appropriate elements in Appendix E, CAPD as a regulatory commitment in Section 4.3 "Personnel Performing accordance with Revision 5 of Maintenance and Testing Activities" no later Procedure OPGP03-ZV-0002.
                                                                                                          ,
than 12/31/2012.  


                                                                        -8 Condition Letter No.         Subject           Record No.       ----
-8 Condition Letter No.
Description of Commitment                   Implementation Status NOC-AE-11002661     Revision to the         11-5788-8*     Identify, document, and implement cyber       Open.
Subject Record No.
and               Facility Operating                     security controls in accordance with the NOC-AE-11002688     License and                           CSP Section 3.1.6 "Mitigation of             The commitment was entered into the (continued)         Request for                           Vulnerabilities and Application of Cyber     CAPO as a regulatory commitment in Review and                             Security Controls" for COAs that could       accordance with Revision 5 of Approval of the                       adversely impact the design function of       Procedure OPGP03-ZV-0002.
Description of Commitment Implementation Status NOC-AE-11002661 Revision to the 11-5788-8*
Cyber Security                         physical security target set equipment.
Identify, document, and implement cyber Open.
Plan The implementation of controls that require a design modification that are not finished by the completion date will be documented in the site configuration management andlor change control program to assure completion of the design modification as soon as possible, but no later than the final implementation date (12/31/2012).             ----
and Facility Operating security controls in accordance with the NOC-AE-11002688 License and CSP Section 3.1.6 "Mitigation of The commitment was entered into the (continued)
11-5788-9*     Ongoing monitoring and assessment             Open.
Request for Vulnerabilities and Application of Cyber CAPO as a regulatory commitment in Review and Security Controls" for COAs that could accordance with Revision 5 of Approval of the adversely impact the design function of Procedure OPGP03-ZV-0002.
activities commence, as described in Section 4.4, "Ongoing Monitoring and         The commitment was entered into the Assessment" of the CSP, for those target     CAPO as a regulatory commitment in set COAs whose security controls have         accordance with Revision 5 of been implemented no later than 12/31/2012. Procedure OPGP03-ZV-0002.
Cyber Security physical security target set equipment.
11-5788-10*     Full implementation of STPNOC CSP for all Open.
Plan The implementation of controls that require a design modification that are not finished by the completion date will be documented in the site configuration management andlor change control program to assure completion of the design modification as soon as possible, but no later than the final implementation date (12/31/2012).
safety, security, or emergency preparedness (SSEP) functions will be achieved by         The commitment was entered into the 2128/2015.                                   CAPO as a regulatory commitment in accordance with Revision 5 of
11-5788-9*
                                                      --
Ongoing monitoring and assessment Open.
Procedure OPGP03-ZV-0002.
activities commence, as described in Section 4.4, "Ongoing Monitoring and The commitment was entered into the Assessment" of the CSP, for those target CAPO as a regulatory commitment in set COAs whose security controls have accordance with Revision 5 of been implemented no later than 12/31/2012. Procedure OPGP03-ZV-0002.
" The Cyber Security Plan (CSP) amendment request was approved by the NRC staff by letter dated July 26, 2011 (ADAMS Accession No. ML111920082). The NRC acknowledged that the licensee made these commitments as a part of the "Cyber Security Plan Implementation Schedule" for the approval of the CSP. However, the NRC staff's safety evaluation for the approval of the CSP stated that the key milestone dates and the final implementation date shall be in accordance with the implementation schedule submitted by the licensee. All subsequent changes to the NRC-approved implementation schedule will require prior NRC approval pursuant to Title 10 of the Code of Federal Regulations (10 CFR),
11-5788-10*
Part 90. Hence, these regulatory commitments are not considered valid anymore and do not need to be tracked. STPNOC was aware of the NRC position and plans to close these commitments.
Full implementation of STPNOC CSP for all Open.
safety, security, or emergency preparedness (SSEP) functions will be achieved by The commitment was entered into the 2128/2015.
CAPO as a regulatory commitment in accordance with Revision 5 of Procedure OPGP03-ZV-0002.
The Cyber Security Plan (CSP) amendment request was approved by the NRC staff by {{letter dated|date=July 26, 2011|text=letter dated July 26, 2011}} (ADAMS Accession No. ML111920082). The NRC acknowledged that the licensee made these commitments as a part of the "Cyber Security Plan Implementation Schedule" for the approval of the CSP. However, the NRC staff's safety evaluation for the approval of the CSP stated that the key milestone dates and the final implementation date shall be in accordance with the implementation schedule submitted by the licensee. All subsequent changes to the NRC-approved implementation schedule will require prior NRC approval pursuant to Title 10 of the Code of Federal Regulations (10 CFR),
Part 90. Hence, these regulatory commitments are not considered valid anymore and do not need to be tracked. STPNOC was aware of the NRC position and plans to close these commitments.  


E. Halpin                                     -2 If you have any questions, please contact me at (301) 415-3016 or via e-mail at Balwant. Singal@nrc.gov.
E. Halpin  
Sincerely, IRAI Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499
- 2 If you have any questions, please contact me at (301) 415-3016 or via e-mail at Balwant. Singal@nrc.gov.
Docket Nos. 50-498 and 50-499  


==Enclosure:==
==Enclosure:==
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PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMSouth Texas Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource ADAMS Accession No. M L 112210658 OFFICE NRR/LPL4           NRR/LPL4/PM     NRR/LPL4/LA     NRR/LPL4/BC NAME    RGrover          BSingal          JBurkhardt      MMarkley         BSingal DATE     8/23/11           8/23/11         8/17/11         9/7111           9/7/11 OFFICIAL RECORD COpy}}
PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMSouth Texas Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource ADAMS Accession No. M L 112210658 Sincerely, IRAI Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation OFFICE NAME NRR/LPL4 RGrover NRR/LPL4/PM BSingal NRR/LPL4/LA JBurkhardt NRR/LPL4/BC MMarkley BSingal DATE 8/23/11 8/23/11 8/17/11 9/7111 9/7/11 OFFICIAL RECORD COpy}}

Latest revision as of 04:54, 13 January 2025

Audit of the Licensee Regulatory Commitment Management Program, Audit Performed July 19-20, 2011
ML112210658
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 09/07/2011
From: Balwant Singal
Plant Licensing Branch IV
To: Halpin E
South Texas
Singal, Balwant, 415-3016, NRR/DORL/LPL4
References
TAC ME6058, TAC ME6059
Download: ML112210658 (16)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 September 7, 2011 Mr. Edward D. Halpin President and Chief Executive Officer!

Chief Nuclear Officer STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483 SUB.JECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - AUDIT OF THE LICENSEE'S REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NOS. ME6058 AND ME6059)

Dear Mr. Halpin:

An audit of South Texas Project (STP), Units 1 and 2, commitment management program was performed at the plant site on July 19-20, 2011. In U.S. Nuclear Regulatory Commission (NRC)

Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

Based on the audit, the NRC staff concludes that STP Nuclear Operating Company (the licensee) has implemented NRC commitments on a timely basis, and the licensee has implemented an effective program for managing NRC commitment changes at STP, Units 1 and 2. The details of the results of the audit including the NRC staff's observations and recommendations are set forth in the enclosed audit report.

E. Halpin

- 2 If you have any questions, please contact me at (301) 415-3016 or via e-mail at Balwant.Singal@nrc.gov.

Sincerely, b~t-4 t~I~~

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499

1.0 INTRODUCTION AND BACKGROUND

In U.S. Nuclear Regulatory Commission (NRC) Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML003741774), the NRC informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that commitments are implemented and that changes to the commitments are evaluated and, when appropriate, reported to NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented.

NEI 99-04 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.). The audit is to be performed once every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of South Texas Project (STP), Units 1 and 2, commitment management program was performed at the plant site on July 19-20, 2011. The audit reviewed commitments made by STP Nuclear Operating Company (STPNOC, the licensee) since the previous audit on August 19, Enclosure

- 2 2008, which was documented in an audit report dated December 24, 2008 (ADAMS Accession No. ML083450162). The audit consisted of two major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, and (2) verification of the licensee's program for managing changes to NRC commitments.

2.1 Verification of Licensee's Implementation of Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.

2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments, as defined above, made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) and licensing activities (bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS for the licensee's submittals since the last audit and selected a representative sample of commitments for verification. The identified list of commitments was forwarded to the licensee on July 6, 2011, with a request to locate documentation for the listed commitments ahead of the NRC staff audit. The licensee did not perform a self-assessment of the commitments identified for this audit.

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

(1)

Commitments made on the licensee's own initiative among internal organizational components.

(2)

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

responding to an NRC request for additional information by a certain date).

Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3)

Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results The licensee has implemented Procedure OPGP05-ZN-0002, Revision 5, "Licensing Commitment Management and Administration," which identifies the methods and responsibilities for the maintenance of commitments and the Regulatory Commitments Management Program, which is used to ensure that the commitments are properly identified, tracked, closed out, revised/changed, or deleted. The licensee uses the program to track the

- 3 status and manage the closure of commitments at STP effectively. The licensee's Procedure OPGPOS-ZN-0002 is consistent with the guidance provided by NEI 99-04.

As discussed above, the licensee's program provides acceptable tools and guidance for the licensee to capture the NRC guidance on commitment management programs. The licensee enters the commitments made to the NRC into the program. The commitments are entered as Condition Records (CRs) in the Corrective Action Program Database (CAPD). The field for "Action Type" in the CR further identifies the CR as a regulatory commitment for the purposes of tracking. The status of the commitments, implementation dates, target implementation document information associated with each specific commitment, and comments are captured in the program.

The documents furnished by the licensee during the audit included summary sheets from the CAPD providing the status of the CR/commitments and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation incorporating the commitments). The NRC staff reviewed the documents and summarized the results of the review of the selected commitments in the attached table to this audit report.

The NRC staff's audit was intended to confirm that the licensee has documented its implementation of commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.

The NRC staffs audit of the licensee's commitment management program for STP, Units 1 and 2, identified the following deficiencies (refer to the attached table to this report for the CR number and description of each individual CR):

Condition Record 08-9676-2S: The CR was not coded as a regulatory commitment as required by the licensee's Procedure OPGPOS-ZN-0002, Revision S. At the conclusion of this audit, the licensee was in the process of correcting the error.

Condition Record 11-S788-2: The commitment was entered into the CAPD as a regulatory commitment, but incorrectly coded as not docketed. At the conclusion of this audit, the licensee was in the process of correcting the error.

The results of the review indicated that the commitments were implemented and/or incorporated satisfactorily and the licensee has an effective commitment management program, with the exception of the deficiencies detailed above. The deficiencies identified above had no safety significance and the licensee was in the process of correcting the deficiencies.

Also, the target document (e.g., procedures) listed the commitments contained in the document in a section entitled "References." To ensure that commitments are not removed or changed in future revisions to the target documents, the target documents clearly identified the areas incorporating specific commitments by reference to the CR number.

-4 Based on the results of the on-site audit, the NRC staff concludes that the licensee has implemented the regulatory commitment management program adequately and consistent with NEI 99-04, except for the deficiencies identified during the audit.

2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes 2.2.1 Audit Scope The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee's process for controlling commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at STP, Units 1 and 2, is contained in Procedure OPGP05-ZN-0002, Revision 5. The primary focus of the audit was to ensure that the commitments are implemented without a change and if a change is made, it is in accordance with the approved plant procedures and with the approval of the plant's management. The audit also verified that the licensee's commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that the licensee's personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.

2.2.2 Audit Results No other commitment changes were identified during the audit, except for changes to the implementation dates for some of the commitments. In all such cases, the licensee generated a Commitment Evaluation Form in accordance with the plant procedures and the review by NRC concluded that the justifications provided by the licensee were adequate.

Based on its review, the NRC staff concludes that the changes to regulatory commitments are being reported to NRC consistent with the NRC guidance.

3.0 OBSERVATIONS AND RECOMMENDATIONS Deficiencies in the commitment management program identified during the NRC audit are identified in Section 2.1.2 of this report. These deficiencies had no safety significance and at the conclusion of the audit, the licensee was in the process of correcting the deficiencies.

However, based on the NRC staff's review, the staff would like to make the following recommendation:

Presently, the CR containing the specific regulatory commitment is identified in the reference section and the body of the target document being revised without any specific markings for the area of change. This makes it difficult to locate the sections of the target document containing regulatory commitments. The licensee agreed to identify the regulatory commitments in the margin area of the target documents (e.g. procedures) for easy traceability and to eliminate the potential for unintentional change to the commitment in future.

- 5

4.0 CONCLUSION

Based on the results of the audit, the NRC staff concludes that the licensee has implemented the commitment management program effectively, and implemented commitment changes appropriately consistent with NEI 99-04. The licensee was in the process of taking action to correct the deficiencies identified during the audit. The deficiencies identified during the audit did not have any safety significance.

5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Marilyn Kistler Wayne Harrison Principal Contributors: B. Singal R. Grover Date: September 7, 2011

Attachment:

Audit Summary Table

Summary of Audit of Regulatory Commitments and Results of Audit Performed on July 19-20, 2011 STP Nuclear Operating Company South Texas Project, Units 1 and 2 Docket Nos. 50-498 and 50-499 Letter No.

Subject Condition Record No.

NOC-AE-08002328 6/26/2008 (ADAMS Accession No. ML081890190)

Request to Extend Implementation Date for Emergency Core Cooling System Sump Design Basis CR 02-5326-111 CR 02-5326-112 CR 02-5326-113 Implementation Status Description of Commitment Closed on 811312008.

or n ore debris load combinations that can be r itigated by the South Texas Project The test will be structured to determine one The commitment was entered into the (STP) sump strainers. (Complete by test Corrective Action Program Database corr pletion date, currently 7/30/2008).

(CAPO) as a regulatory commitment.

The results of the test specified in the Condition Record (CR) were acceptable and, as a result, the CR was closed.

+-1

~

STF will consider contingencies listed in the Closed on 8/13/2008.

cov r letter should strainer testing not den onstrate satisfactory performance.

The commitment was entered into the (Complete by test completion date, currently CAPO as a regulatory commitment.

7/3( 12008).

The results of the strainer test specified in the CR were determined to be acceptable and the CR was closed.

11-------'-----**

Tes ng plan and contingency options Open.

pr01 de assurance that the Generic Safety ISSl e (GSI)-191 and Generic Letter (GL)

The commitment was entered into the 200 -02 issues will be resolved for STP, CAPO as a regulatory commitment.

Unil s 1 and 2, by 12/31/2009.

The completion date was changed to 4/1/2012. Commitment Evaluation Form documenting the justification for the extension was reviewed and the I ch<3~ge was found acceptable.

~

Attachment

- 2 Subject Letter No.

NOC-AE-08002372 12/11/2008 (ADAMS Accession No. ML083520326)

NOC-AE-09002389 31312009 (ADAMS Accession No. ML090690687)

NOC-AE-09002477 10/14/2009 (ADAMS Accession No. ML092930172)

Response to Generic Letter 2004-02 License Amendment Request for Adoption of TSTF-511.

Revision 0, "Eliminate Working Hour Restrictions From TS 5.2.2 To Support Compliance With 10 CFR Part 26."

Revised Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue Condition Record No.

CR 02-5326-120 09-1587-2 09-10811-4 Description of Commitment When a final Safety Evaluation for WCAP-16793. "Long Term Cooling" is issued, STP will review it for impact on its long-term cooling methodology.

Expected completion date: 6/30/2009.

Removal of the plant-specific Technical Specification (TS) requirements will be performed concurrently with the implementation of the 10 CFR Part 26.

Subpart I requirements. This commitment will be completed no later than the implementation deadline of 10/1/2009.

When the Fitness for Duty Rule for Managing Fatigue is changed and an exemption from the requirements of 10 CFR 26.205(c) and (d) for meeting work hour controls during declarations of severe weather conditions involving tropical storm or hurricane force winds is no longer needed, STP Nuclear Operating Company (STPNOC) will submit a letter to the NRC stating that the exemption is no longer needed by 12/3112011.

Implementation Status Open.

The commitment is identified as a regulatory commitment in the CAPD.

The commitment completion date has been changed to 12/15/2011. The Commitment Evaluation Form justifying the change in completion date was reviewed and the change was found acceptable.

Closed on 10/1/2009.

The commitment was identified as a regulatory commitment in the CAPD.

The commitment is fully met as reflected in TS Amendment Nos. 192 for STP, Unit 1, and 180 for STP.

Unit 2.

Open.

The commitment is identified as a regulatory commitment in the CAPD.

The licensee has already received approval for the exemption. However, the licensee needs to issue a letter to the NRC by 12/31/2011. to confirm that the exemption is no longer required.

-3 r~~

Letter No.

Subject Condition Record No.

Description of Commitment Implementation Status NOC-AE-09002480 11/19/2009 (ADAMS Accession No. ML093280720)

License Amendment Request for Approval of Cyber Security Plan 09-10761-6 STPNOC will have implemented the requirements of 10 CFR 73.54. 60 months after NRC approval of the STPNOC Cyber Security Plan.

Closed on 7/26/2010.

The commitment was entered into the CAPO as a regulatory commitment.

The license amendment request was withdrawn by the licensee by letter dated 7/27/2010 (ADAMS Accession No. ML102150159). and the commitment is no longer valid.

NOC-AE-10002558 5/10/2010 (ADAMS Accession No. ML101340116)

Licensee Commitment Regarding a Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue 09-10811-9 The conditions necessary to sequester site personnel that are consistent with the conditions specified in the exemption request (NOC-AE-09002477. ADAMS Accession No. ML092930172). on approval of the request for exemption will be maintained in the site procedures.

Closed on 8/31/2010.

The commitment is identified as a regulatory commitment in the CAPO.

Procedure OPGP03-ZV-0002.

Revision 5 incorporates the commitment.

09-10811-9 Provisions for ensuring that personnel who are not performing duties are provided an opportunity as well as accommodations for restorative rest on approval of the request for exemption will be maintained in the site procedures.

Closed on 8/3112010.

The commitment is identified as a regulatory commitment in the CAPO.

Procedure OPGP03-ZV-0002, I

Revision 5 incorporates the commitment.

09-10811-9 The condition for departure from the exemption is based on the Emergency Operations Facility Director's determination that adequate staffing is available to meet the requirements of 10 CFR 26.205(c) and (d) on approval of the request for exemption will be maintained in the site procedures.

Closed on 8/31/2010.

The commitment is identified as a regulatory commitment in the CAPO.

Procedure OPGP03-ZV-0002. Revision 5 incorporates the commitment.

~---~ --~~

I

-4 Condition Letter No.

Subject Record No.

Description of Commitment Implementation Status NOC-AE-10002594 Request for 08-9676-25 If a containment spray (CS), low head safety Closed on 10/27/2010.

9/20/2010 (ADAMS Relief from injection (LHSI), or high head safety Accession No.

ASME Section XI injection (HHSI) pump is disassembled Verified procedure OPGP03-ZE-0027 ML102700175)

Code during the third inspection interval, STPNOC (Revision 29), Addendum 6, Section Requirements for will perform the Code-required surface 5.0. The commitment was entered into Pump Casing examination of the pump casing welds the CAPO as CR 8-9676-25, but was Inservice within the pump pit by 12/12/2010 not coded as a regulatory commitment.

Inspection (incorporation into procedure).

The licensee was in the process of Examination correcting the error.

NOC-AE-10002623 Revision to 10-24696-03 Lead Test Assembly (LTA) measured data Open.

12/21/2010 Technical and favorable results from visual (ADAMS Specifications examinations of once, twice, and thrice Commitment entered into CAPO as a Accession No.

5.3.1 and 6.9.1.6 burned L T As confirm, for three cycles of regulatory commitment.

ML103630408) to Allow Fuel operation, that the current fuel performance Assemblies with models are applicable for Optimized The commitment to be incorporated Optimized ZIRLO' clad fuel rods. Westinghouse will prior to loading fuel rods with ZIRLO' continue to provide additional data from the Optimized ZIRLO' cladding.

Cladding Optimized ZIRLO' L TA programs to the NRC as it becomes available.

It is stated in the commitment that confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLO' fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. It further states that until the commitment is complete, STPNOC will confirm that, as higher burnupslfluences are achieved for Optimized ZIRLO' clad fuel rods, the requirements of this condition are met as it applies to STP, Units 1 and 2.

- 5 Condition Letter No.

Description of Commitment Implementation Status Subject Record No.

Data from three cycles of operation have Open.

Technical NOC-AE-10002623 Revision to 10-24696-04 been evaluated and the fuel rod creep (continued) models from fuel rod design codes have Verified the CAPO. Commitment Specifications been used to predict growth and creep entered into CAPO as a regulatory to Allow Fuel 5.3.1 and 6.9.1.6 performance of the samples. This commitment Assemblies with information was provided to the NRC in the Optimized The commitment to be incorporated ZIRLO' most recent informational letter (V L TR-prior to loading fuel rods with Cladding NRC-10-43) dated 7/26/2010. Confirmation Optimized ZIRLO' cladding.

through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. Until the commitment is complete, STPNOC will confirm that the requirements of this condition are met as it applies to STP, Units 1 and 2.

10-24696-05 of the approved models' applicability up The relative differences in unirradiated Open.

strength (YS and UTS) between Optimized ZIRLO' and standard ZIRLO' in cladding Verified the CAPO. Commitment and structural analyses will be accounted for entered into CAPO as a regulatory until irradiation data for Optimized ZIRLO' commitment.

is accepted by the NRC staff. Analysis of Optimized ZIRLO' clad fuel rods will use The commitment to be incorporated the yield strength and ultimate tensile prior to loading fuel rods with strength as modified per Conditions a.a.i, Optimized ZIRLO' cladding.

a.a.H, and a.a.iii until such time that irradiation data for Optimized ZIRLO' strengths are collected and provided to the NRC.

Until the values are accepted by the NRC, STPNOC will confirm that the requirements of this condition are met as it applies to STP, Units 1 and 2.

-6 Letter No.

Subject Condition Record No.

Description of Commitment Implementation Status NOC-AE-11002661 4/412011 (ADAMS Accession No. ML111090384) and NOC-AE-11002688 6/28/2011 (ADAMS Accession No. ML11182A911)

Revision to the Facility Operating License and Request for Review and Approval of the Cyber Security Plan 11-5788-2*

STPNOC will revise its License Amendment Request for approval of the Cyber Security Plan (submitted to the NRC on 7/27/2010; ADAMS Accession No. ML102150159) by inserting the following words into section 2.1 of the Cyber Security Plan (CSP):

"Within the scope of NRC's cyber security rule at Title 10 of the Code ofFederal Regulations (10 CFR) 73.54, systems or equipment that perform important to safety functions include structures, systems, and components (SSCs) in the balance of plant (BOP) that could directly or indirectly affect reactivity at a nuclear power plant and could result in an unplanned reactor shutdown or transient. Additionally, these SSCs are under the licensee's control and include electrical distribution equipment out to the first inter-tie with the offsite distribution system." "No later than December 31, 2012."

Closed on 4/28/2011.

The commitment was entered into the CAPD as a regulatory commitment, but incorrectly coded as not docketed.

Verified STPNOC letter dated 4/28/2011 (ADAMS Accession No. ML11123A217) incorporating the commitment.

11-5788-3*

Establish Cyber Security Assessment Team (CSAT) as described in Section 3.1.2 "Cyber Security Assessment Team" of the CSP no later than 12/31/2012.

Closed on 7/11/2011.

The commitment was entered into the CAPD as a regulatory commitment.

Verified that STPNOC has already established the cyber security team roster.

11-5788-4*

Identify Critical Systems (CSs) and Critical Digital Assets (CDAs) as described in Section 3.1.3 "Identification of Critical Digital Assets" of the CSP no later than 12/31/2012.

Closed on 7/1112011.

The commitment was entered into the CAPD as a regulatory commitment.

Verified STPNOC has already identified CSs and CDAs as described in Section 3.1.3 of the CSP. However, the detailed description of the CSs and CDAs was not reviewed, being a security-related document.

- 7 Condition Description of Commitment Implementation Status Letter No.

Subject Record No.

11-5788-5*

Implement Installation of a deterministic Open.

and NOC-AE-11002661 Revision to the Facility Operating one-way device between lower level devices NOC-AE-11002688 The commitment was entered into the (continued)

(level 2 and 3) and a firewall between higher License and CAPD as a regulatory commitment in Review and Request for level devices (level 3 and 4) as described in Section 4.3, "Defense-In-Depth Protective accordance with Revision 5 of Approval of the Procedure OPGP03-ZV-0002.

Cyber Security Plan Strategies" of the CSP.

Lower security level devices ([level 0, 1, 2 devices]) that bypass the deterministic device and connect to level 3 or 4 will be modified to prevent the digital connectivity to the higher level or will be modified to meet cyber security requirements commensurate with the level [3 or 4] devices to which they connect.

The design modifications that are not finished by the completion date will be documented in the site configuration management andlor change control program to assure completion of the design modification as soon as possible, but no later than the final implementation date (12/31/2012).

The security control "Access Control For Open.

Portable And Mobile Devices" described in Appendix D 1.19 of NEI 08-09, Revision 6, 11-5788-6*

The commitment was entered into the will be implemented no later than CAPD as a regulatory commitment in accordance with Revision 5 of Procedure OPGP03-ZV-0002.

11-5788-7*

12/31/2012.

Open.

obvious cyber related tampering to existing insider mitigation rounds by incorporating Implement observation and identification of The commitment was entered into the the appropriate elements in Appendix E, CAPD as a regulatory commitment in Section 4.3 "Personnel Performing accordance with Revision 5 of Maintenance and Testing Activities" no later Procedure OPGP03-ZV-0002.

than 12/31/2012.

-8 Condition Letter No.

Subject Record No.

Description of Commitment Implementation Status NOC-AE-11002661 Revision to the 11-5788-8*

Identify, document, and implement cyber Open.

and Facility Operating security controls in accordance with the NOC-AE-11002688 License and CSP Section 3.1.6 "Mitigation of The commitment was entered into the (continued)

Request for Vulnerabilities and Application of Cyber CAPO as a regulatory commitment in Review and Security Controls" for COAs that could accordance with Revision 5 of Approval of the adversely impact the design function of Procedure OPGP03-ZV-0002.

Cyber Security physical security target set equipment.

Plan The implementation of controls that require a design modification that are not finished by the completion date will be documented in the site configuration management andlor change control program to assure completion of the design modification as soon as possible, but no later than the final implementation date (12/31/2012).

11-5788-9*

Ongoing monitoring and assessment Open.

activities commence, as described in Section 4.4, "Ongoing Monitoring and The commitment was entered into the Assessment" of the CSP, for those target CAPO as a regulatory commitment in set COAs whose security controls have accordance with Revision 5 of been implemented no later than 12/31/2012. Procedure OPGP03-ZV-0002.

11-5788-10*

Full implementation of STPNOC CSP for all Open.

safety, security, or emergency preparedness (SSEP) functions will be achieved by The commitment was entered into the 2128/2015.

CAPO as a regulatory commitment in accordance with Revision 5 of Procedure OPGP03-ZV-0002.

The Cyber Security Plan (CSP) amendment request was approved by the NRC staff by letter dated July 26, 2011 (ADAMS Accession No. ML111920082). The NRC acknowledged that the licensee made these commitments as a part of the "Cyber Security Plan Implementation Schedule" for the approval of the CSP. However, the NRC staff's safety evaluation for the approval of the CSP stated that the key milestone dates and the final implementation date shall be in accordance with the implementation schedule submitted by the licensee. All subsequent changes to the NRC-approved implementation schedule will require prior NRC approval pursuant to Title 10 of the Code of Federal Regulations (10 CFR),

Part 90. Hence, these regulatory commitments are not considered valid anymore and do not need to be tracked. STPNOC was aware of the NRC position and plans to close these commitments.

E. Halpin

- 2 If you have any questions, please contact me at (301) 415-3016 or via e-mail at Balwant. Singal@nrc.gov.

Docket Nos. 50-498 and 50-499

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrPMSouth Texas Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource ADAMS Accession No. M L 112210658 Sincerely, IRAI Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation OFFICE NAME NRR/LPL4 RGrover NRR/LPL4/PM BSingal NRR/LPL4/LA JBurkhardt NRR/LPL4/BC MMarkley BSingal DATE 8/23/11 8/23/11 8/17/11 9/7111 9/7/11 OFFICIAL RECORD COpy

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