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| number = ML090570036
| number = ML090570036
| issue date = 02/27/2009
| issue date = 02/27/2009
| title = (OCNGS) - Audit of the Exelon'S Management of Regulatory Commitments
| title = (OCNGS) - Audit of the Exelons Management of Regulatory Commitments
| author name = Miller G E
| author name = Miller G
| author affiliation = NRC/NRR/DORL/LPLI-2
| author affiliation = NRC/NRR/DORL/LPLI-2
| addressee name = Pardee C G
| addressee name = Pardee C
| addressee affiliation = Exelon Generation Co, LLC
| addressee affiliation = Exelon Generation Co, LLC
| docket = 05000219
| docket = 05000219
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY  
{{#Wiki_filter:UNITED STATES 
NUCLEAR REGULATORY COMMISSION 
WASHINGTON, D.C. 20555-0001  
WASHINGTON, D.C. 20555-0001  
February 27, 2009 Mr. Charles G.  
February 27, 2009  
Pardee President  
Mr. Charles G. Pardee
and Chief Nuclear Officer Exelon Generation  
President and Chief Nuclear Officer  
Company 4300 Winfield Road Warrenville, IL 60555 SUB..OYSTER CREEK NUCLEAR GENERATING  
Exelon Generation Company
STATION (OCNGS) -AUDIT OF EXELON'S MANAGEMENT  
4300 Winfield Road  
OF REGULATORY  
Warrenville, IL 60555  
COMMITMENTS (TAC NO. ME0362) Dear Mr. Pardee:  
SUB..IECT 
In Regulatory  
OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF  
Issue Summary 2000-17, "Managing  
EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.  
Regulatory  
ME0362)  
Commitments Made by Power  
Dear Mr. Pardee:  
Reactor Licensees to the NRC Staff," dated  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power  
September  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory  
21,2000, the U. S.  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,  
Nuclear Regulatory  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for  
Commission (NRC) informed licensees that the Nuclear Energy Institute  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or  
document NEI 99-04, "Guidelines  
similar administrative controls to ensure that regulatory commitments are implemented and that  
for Managing NRC Commitment  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the  
Changes," contains acceptable  
NRC.  
guidance for controlling  
The NRC Office of Nuclear Reactor Requtation has instructed its staff to perform an audit of  
regulatory  
licensees' commitment management programs once every 3 years to determine whether the  
commitments  
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory  
and encouraged  
commitments are being effectively implemented.  
licensees to use the NEI  
An audit of OCNGS's commitment management program was performed during January and  
guidance or similar administrative  
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,  
controls to ensure that regulatory  
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
commitments  
acceptable program for implementing and managing NRC commitments. Details of the audit  
are implemented and that changes to the regulatory  
are set forth in the enclosed audit report.  
commitments  
G. dward Miller, Project Man ger  
are evaluated and, when  
Plant Licensing Branch 1-2  
appropriate, reported to the NRC. The NRC Office of  
Division of Operating Reactor Licensing  
Nuclear Reactor Requtation has  
Office of Nuclear Reactor Regulation  
instructed  
Docket No. 50-219  
its staff to perform an  
Enclosure: Audit Report  
audit of licensees'  
cc w/encl: Distribution via ListServ  
commitment  
 
management  
UNITED STATES  
programs once every 3 years to determine  
NUCLEAR REGULATORY COMMISSION 
whether the licensees'  
programs are consistent with the industry guidance in NEI 99-04, and  
that regulatory  
commitments are being  
effectively  
implemented. An audit of  
OCNGS's commitment  
management program was  
performed  
during January and February 2009, including  
activities  
at Exelon's office in  
Kennett Square, PA on February 24, 2009. The NRC  
staff concludes, based on the audit, that OCNGS has implemented  
an acceptable program for  
implementing  
and managing NRC commitments. Details of the audit are set forth in the  
enclosed audit report. G. dward Miller, Project Man ger Plant Licensing  
Branch 1-2 Division of  
Operating  
Reactor Licensing Office of  
Nuclear Reactor Regulation  
Docket No. 50-219 Enclosure:  
Audit Report cc w/encl: Distribution  
via ListServ   
UNITED NUCLEAR REGULATORY  
WASHINGTON, D.C. 20555-0001  
WASHINGTON, D.C. 20555-0001  
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION  
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION  
LICENSEE MANAGEMENT  
LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS  
OF REGULATORY  
OYSTER CREEK NUCLEAR GENERATING STATION
COMMITMENTS  
DOCKET NO. 50-219  
OYSTER CREEK NUCLEAR GENERATING  
1.0  
STATION DOCKET NO. 50-219 1.0 INTRODUCTION  
INTRODUCTION AND BACKGROUND  
AND BACKGROUND  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power  
In Regulatory  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory  
Issue Summary 2000-17, "Managing  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,  
Regulatory  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for  
Commitments  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or  
Made by Power Reactor Licensees to the NRC Staff," dated September  
similar administrative controls to ensure that regulatory commitments are implemented and that  
21,2000, the U. S.  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the  
Nuclear Regulatory  
NRC.  
Commission (NRC) informed licensees that the Nuclear Energy Institute  
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit  
document NEI 99-04, "Guidelines  
of licensees' commitment management programs once every 3 years to determine whether the  
for Managing NRC Commitment  
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory  
Changes," contains acceptable  
commitments are being effectively implemented.  
guidance for controlling  
NEI-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action  
regulatory  
agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.  
commitments  
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment  
and encouraged  
management program by assessing the adequacy of the licensee's implementation of a sample  
licensees to use the NEI  
of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions,  
guidance or similar administrative  
etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.  
controls to ensure that regulatory  
2.0  
commitments  
AUDIT PROCEDURE AND RESULTS  
are implemented and that changes to the regulatory  
An audit of the Oyster Creek Nuclear Generating Station (OCNGS) commitment management  
commitments  
program was performed at the NRC Headquarters using documentation provided by the  
are evaluated  
licensee and at the licensee's Kennett Square office during the period of January and February  
and, when appropriate, reported to the NRC. The NRC Office of Nuclear Reactor Regulation (NRR) has instructed  
2009. The audit reviewed commitments made since the previous audit in January 2004. The  
its staff to perform an audit of licensees'  
audit consisted of two major parts: (1) verification of the licensee's implementation of NRC  
commitment  
commitments that have been completed, and (2) verification of the licensee's program for  
management  
managing changes to NRC commitments.  
programs once every 3 years to determine  
Enclosure  
whether the licensees'  
 
programs are consistent with the industry guidance in NEI 99-04, and that regulatory  
- 2
commitments are being  
2.1 
effectively  
Verification of Licensee's Implementation of NRC Commitments  
implemented.  
The primary focus of this part of the audit is to confirm that the licensee has implemented  
NEI-99-04  
commitments made to the NRC as part of past licensing actions/activities. For commitments not  
defines a "regulatory  
yet implemented, the NRC staff determines whether they have been captured in an effective
commitment" as an explicit statement  
program for future implementation.
to take a specific action agreed to, or volunteered by, a licensee and submitted  
2.1.1  Audit Scope  
in writing on the docket to the NRC.  
The audit addressed a sample of commitments made during the review period. The audit  
NRR guidelines  
focused on regulatory commitments (as defined above) made in writing to the NRC as a result  
direct the NRR Project Manager to audit the licensee's  
of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins,  
commitment  
generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices  
management  
of Violation may be included in the sample, but the review will be limited to verification of  
program by assessing  
restoration of compliance, not the specific methods used. Before the audit, the NRC staff
the adequacy of the licensee's  
searched the Agencywide Documents Access and Management System (ADAMS) for the  
implementation of a sample of commitments  
licensee's submittals since the last audit and selected a representative sample for verification.  
made to the NRC in past licensing  
The audit excluded the following types of commitments that are internal to licensee processes:  
actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.). The  
(1) 
audit is to be performed  
Commitments made on the licensee's own initiative among internal organizational  
every 3 years. 2.0 AUDIT PROCEDURE  
components. (Note: the internal self-assessment and subsequent transition to the  
AND RESULTS An audit of the Oyster Creek Nuclear Generating  
Exelon Passport program was audited as an indicator of the commitment to the  
Station (OCNGS) commitment  
process.)  
management  
(2) 
program was performed at the NRC Headquarters  
Commitments that pertain to milestones of licensing actions/activities (e.g., respond to  
using documentation  
an NRC request for additional information by a certain date). Fulfillment of these  
provided by the licensee and at the  
commitments was indicated by the fact that the subject licensing action/activity was
licensee's  
completed.  
Kennett Square office during the period of January and February 2009. The  
(3) 
audit reviewed commitments  
Commitments made as an internal reminder to take actions to comply with existing  
made since the  
regulatory requirements such as regulations, technical specifications, and updated final  
previous audit in January 2004. The  
safety analysis reports. Fulfillment of these commitments was indicated by the licensee  
audit consisted of two major parts: (1)  
having taken timely action in accordance with the subject requirements.  
verification of the licensee's  
2.1.2 
implementation of NRC commitments  
Audit Results  
that have been completed, and (2) verification of the licensee's  
Table 1 contains a list of those documents that were selected for additional review during this  
program for managing changes to NRC commitments.  
audit.  
Enclosure
The NRC staff found that the licensee's commitment tracking program had captured all the  
-2Verification
regulatory commitments that were identified by the NRC staff before the audit. The NRC staff  
of Licensee's  
also reviewed plant procedures, assessment recommendations, work orders, corrective actions,  
Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the  
training, qualification certifications and action requests that had been initiated or revised as a  
licensee has implemented  
result of commitments made by the licensee to NRC.  
commitments made to the NRC as part of past licensing  
The program has a requirement that the licensee perform an annual review and assessment of
actions/activities. For commitments not yet implemented, the NRC  
site and corporate commitments. The most recent OCNGS annual review was reviewed by the  
staff determines  
 
whether they have been captured in an  
- 3
effective program for future  
NRC staff. The annual review appeared thorough, addressing over 300 items. It identified  
implementation. Audit Scope The audit addressed a sample of  
isolated concerns with procedure annotation. Further, the NRC staff found that appropriate  
commitments made during the  
corrective actions were initiated.  
review period. The audit focused on  
2.2  
regulatory  
Verification of the Licensee's Program for Managing NRC Commitment Changes
commitments (as defined  
The primary focus of this part of the audit is to verify that the licensee has established
above) made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.).  
administrative controls for modifying or deleting commitments made to the NRC. The NRC staff
Commitments made in Licensee  
compared the licensee's process for controlling regulatory commitments to the guidelines in
Event Reports or in response to Notices of Violation may be included in the sample, but the  
NEI-99-04, which the NRC has found to be an acceptable guide for licensees to follow for
review will be limited to verification of restoration of  
managing and changing commitments. The process used at OCNGS is contained in LS-AA
compliance, not the specific methods used. Before the audit, the NRC  
110 - Revision 6, "Commitment Management." The audit reviewed a sample of commitment
staff searched the  
changes that included changes that were or will be reported to the NRC, and changes that were
Agencywide  
not or will not be reported to the NRC. The audit also verifies that the licensee's commitment
Documents Access and  
management system includes a mechanism to ensure traceability of commitments following
Management  
initial implementation. This ensures that licensee personnel are able to recognize that future
System (ADAMS) for the licensee's  
proposed changes to the affected design features or operating practices require evaluation in
submittals since the last audit and selected a  
accordance with the commitment change control process.
representative sample for verification. The audit excluded the  
2.2.1
following types of commitments that are internal to licensee processes: Commitments made on the  
Audit Results
licensee's own initiative  
Table 1 contains a list of those documents that were selected for additional review during this
among internal organizational  
audit.
components. (Note: the internal  
The NRC staff reviewed the licensee's procedure LS-AA-110, Revision 6,. Section 6.1 of the
self-assessment  
procedure lists NEI 99-04 as a reference. The NRC staff found that LS-AA-11 0 generally
and subsequent transition to the Exelon Passport program was audited as an  
follows the guidance of NEI 99-04 and provides detailed instructions for making regulatory
indicator of the commitment to the process.) Commitments that pertain to  
commitments, tracking regulatory commitments, annotating documents to provide traceability of
milestones of licensing  
commitments, and for making changes to commitments. Therefore, the NRC staff concludes
actions/activities (e.g., respond to an NRC request for  
that the procedure used by the licensee to manage commitments provides the necessary
additional  
attributes for an acceptable commitment management program.
information by a certain date).  
The NRC Staff noted that a self-assessment had been performed since the last NRC audit and
Fulfillment of these commitments  
the potential concern identified in the previous NRC audit about the use of multiple commitment
was indicated by the fact that the  
tracking systems was addressed. Three recommendations from the self-assessment were
subject licensing  
entered into the commitment tracking program and acted upon. One of the recommendations
action/activity  
that OCNGS transition to the Passport tracking program (Exelon fleet-wide system) from the
was completed. Commitments made as an internal reminder to take  
use of multiple programs addressed the previous potential concern. Another recommendation
actions to comply with existing  
addressed verification of proper annotation after the transfer. Related procedure
regulatory  
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport,"
requirements such as regulations, technical  
was also reviewed.
specifications, and updated final  
The NRC staff also reviewed documents that had been created or revised as a result of
safety analysis reports.  
commitments made by the licensee to the NRC. The staff noted that, except as noted below,
Fulfillment of these commitments was indicated by the licensee  
the revised documents have annotations referring to commitments as part of the commitment
having taken timely action in accordance  
change control process. These annotations serve to prevent the commitments from
with the subject requirements. Audit Results Table 1 contains a list of those  
inadvertently being deleted or altered without having gone through the commitment change
documents that were selected for  
process. The NRC observed that in response to one commitment (Item 1 in Table 1)
additional  
 
review during this  
- 4
audit. The NRC staff found that the  
emergency procedures were revised, an operations briefing developed and the training program
licensee's  
augmented. It was further observed that one of the revised procedures, 2000-GLN-3200.01
commitment  
(Plant Specific Technical Guidelines for the Symptom Based Emergency Operating Procedures)
tracking program had captured all the  
was annotated consistent with the procedural requirements. However, the "EOP Support
regulatory  
Procedure 7" referenced in the commitment (and referenced by 2000-GLN-3200.01) was not
commitments that were identified by the NRC staff before the audit. The NRC staff also reviewed plant  
annotated. As a result of discussions during this audit, an entry was made into the corrective
procedures, assessment  
action program to evaluate the annotation requirements and determine if there are any
recommendations, work orders, corrective  
extended implications.
actions, training, qualification  
3.0
certifications and action requests that had been initiated or revised as a result of  
CONCLUSION
commitments made by the licensee to NRC. The program has a  
As discussed above, the licensee's procedure used to implement and manage commitments
requirement that the licensee perform an annual  
provides the necessary attributes for an acceptable commitment management program.
review and assessment  
4.0
of site and corporate  
LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
commitments. The most recent OCNGS annual  
Richard Gropp
review was reviewed by the
Calvin Taylor
-NRC staff. The annual review appeared thorough, addressing over 300 items. It identified isolated concerns with  
John Hufnagel
procedure annotation. Further, the NRC  
Pam Cowan
staff found that appropriate corrective actions were initiated.  
Principal Contributor: D. Egan
2.2 Verification of the Licensee's Program for Managing NRC  
 
- 5
Item
Source
Commitment  
Commitment  
Changes The primary focus of this part of the audit is to verify that the licensee has
established
administrative controls for
modifying or deleting
commitments made to the NRC. The NRC staff compared the
licensee's
process for controlling
regulatory
commitments to the guidelines
in NEI-99-04, which the NRC has found to be an
acceptable guide for
licensees to follow for managing and changing
commitments. The process used at
OCNGS is contained in 110 -Revision 6, "Commitment
Management." The audit reviewed a sample of
commitment changes that included
changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The audit also verifies that the
licensee's
commitment
management
system includes a mechanism to ensure
traceability
of commitments
following
initial implementation.
This ensures that licensee personnel are able to recognize that future proposed changes to the
affected design features or operating
practices require evaluation in
accordance with the commitment change control process.
2.2.1 Audit Results Table 1 contains a list of those
documents that were selected for
additional review during this
audit. The NRC staff reviewed the
licensee's procedure LS-AA-110, Revision 6,. Section 6.1 of the procedure lists NEI 99-04 as a reference. The NRC
staff found that LS-AA-11 0
generally follows the
guidance of NEI 99-04 and provides detailed
instructions for making regulatory commitments, tracking
regulatory
commitments, annotating
documents to provide
traceability
of commitments, and for making
changes to commitments.
Therefore, the NRC staff concludes that the procedure used by the
licensee to manage
commitments provides the
necessary attributes for an
acceptable
commitment
management
program. The NRC Staff noted that a
self-assessment had been performed since the last NRC audit and the potential concern identified in the previous NRC audit about the use of multiple
commitment
tracking systems was addressed.
Three recommendations from the self-assessment
were entered into the
commitment tracking program and acted upon. One of the
recommendations that OCNGS
transition to the Passport tracking program (Exelon
fleet-wide
system) from the use of multiple
programs addressed the previous potential concern.
Another recommendation
addressed
verification
of proper annotation after the transfer. Related
procedure
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport," was also reviewed. The NRC staff also reviewed
documents that had been created or revised as a result of
commitments made by the
licensee to the NRC. The
staff noted that, except as noted below, the revised
documents
have annotations referring to
commitments as part of the
commitment change control process.
These annotations serve to prevent the
commitments
from inadvertently being deleted or altered without having gone through the
commitment
change process. The NRC observed that in response to one
commitment (Item 1 in Table 1) 
-emergency
procedures were revised, an operations briefing
developed and the training program augmented. It was
further observed that one of the revised
procedures, 2000-GLN-3200.01 (Plant Specific
Technical
Guidelines for the Symptom Based
Emergency Operating Procedures) was annotated
consistent with the procedural requirements. However, the "EOP Support
Procedure
7" referenced in the
commitment (and referenced by
2000-GLN-3200.01) was not annotated. As a result of
discussions during this audit, an entry was made into the corrective action program to evaluate the annotation
requirements
and determine if there are any extended implications.
3.0 CONCLUSION As discussed above, the
licensee's procedure used to
implement and manage commitments provides the
necessary
attributes for an acceptable
commitment
management
program. 4.0 LICENSEE PERSONNEL
CONTACTED FOR THIS AUDIT Richard Gropp
Calvin Taylor John Hufnagel Pam Cowan Principal Contributor: D. Egan 
-Item Source Commitment
Timeframe  
Timeframe  
Comments 1 Source: 1/24/07 letter 20448, Summary of Commitments. Second item. (ML07031 01010) Oyster Creek [emergency  
Comments  
operations  
1  
procedure]  
Source: 1/24/07  
EOP Support Procedure 7 will be revised to direct the  
letter 2130-07
Operator to inject the entire  
20448,  
contents of the Liquid Poison tank in the event that a [loss  
Summary of  
of coolant accident]  
Commitments.  
LOCA is in progress. Include these EOP  
Second item.  
changes and their basis in Licensed  
(ML07031 01010)  
Operator Training, and update the EOP User's Guide to include the use of sodium pentaborate for pH control of the  
Oyster Creek [emergency operations procedure] EOP
suppression  
Support Procedure 7 will be revised to direct the  
pool under LOCA conditions.  
Operator to inject the entire contents of the Liquid Poison  
Upon implementation  
tank in the event that a [loss of coolant accident] LOCA is  
of approved amendment.  
in progress. Include these EOP changes and their basis  
in Licensed Operator Training, and update the EOP  
User's Guide to include the use of sodium pentaborate  
for pH control of the suppression pool under LOCA  
conditions.  
Upon  
implementation  
of approved  
amendment.  
Procedure  
Procedure  
EMG-SP7 -not annotated (revised parent document annotated)  
EMG-SP7 - not annotated  
(revised parent document  
annotated)  
RCMT 189765-48  
RCMT 189765-48  
2 Source: 7/3/08 letter 060, Attachment 2. First item on page 9 and last  
2  
item on page 10. (ML0819308020) First item on page 9:  
Source: 7/3/08  
Oyster Creek will  
letter RA-08
follow the guidelines in Section  
060, Attachment  
11.3.6.5 of NUMARC 93-01, Rev. 3 during refueling within  
2. First item on  
containment.  
page 9 and last  
Plant procedures will be revised, as  
item on page 10.  
appropriate, to implement  
(ML0819308020)  
these guidelines. Last item on oaae 10: The  
First item on page 9: Oyster Creek will follow the  
following  
guidelines in Section 11.3.6.5 of NUMARC 93-01, Rev. 3  
secondary  
during refueling within containment. Plant procedures  
containment  
will be revised, as appropriate, to implement these
potential  
guidelines.  
openings will remain closed during refueling activities  
Last item on oaae 10: The following secondary  
under administrative  
containment potential openings will remain closed during  
controls:  
refueling activities under administrative controls:  
* Ventilation  
*  
ductwork below siding  
Ventilation ductwork below siding structure on
structure  
west side of Reactor Building (north end of west  
on west side of  
wall)  
Reactor Building (north end of west  
*  
wall) * Ventilation  
Ventilation ductwork below siding structure on
ductwork below siding  
west side of Reactor Building (south end of west  
structure  
wall)  
on west side  
*  
of Reactor Building (south end of west  
Trunion Room Doors to Turbine Building  
wall) * Trunion Room Doors to  
*  
Turbine Building * Reactor Building  
Reactor Building Commodities (flanged)  
Commodities (flanged) penetration on north RB wall  
penetration on north RB wall  
* MAC Facility Doors  
*  
Upon implementation  
MAC Facility Doors  
of approved amendment. Note: This  
Upon  
License Amendment
implementation  
Request has not been approved.
of approved  
The commitments
amendment.  
associated with License  
Note: This  
License  
Amendment  
Amendment  
Request has
not been
approved.
The commitments associated
with License Amendment
Request are being tracked  
Request are being tracked  
under Passport Action Requests 642132 and 828005. This issue is still  
under Passport Action  
under review by the NRC. The  
Requests 642132 and  
commitments  
828005.  
associated  
This issue is still under review  
with this License  
by the NRC. The  
Amendment  
commitments associated with
this License Amendment  
Request will be implemented  
Request will be implemented  
as approved by the NRC.  
as approved by the NRC.  
Table 1
Table 1  
-6 Item Source Commitment  
 
- 6  
Item Source  
Commitment  
Timeframe  
Timeframe  
Comments 3 Source; 2/2/07 letter 20450, Page 4.  
Comments  
Corrective action planned  
3  
item. (ML0703803170) The new pressure switch  
Source; 2/2/07  
performance will be monitored for a year to  
letter 2130-07
determine  
20450, Page 4.  
if periodic replacement of the pressure switches is  
Corrective  
warranted. One year after  
action planned  
[license event report] LER  
item.  
(ML0703803170)  
The new pressure switch performance will be monitored  
for a year to determine if periodic replacement of the  
pressure switches is warranted.  
One year after  
[license event  
report] LER  
submittal.  
submittal.  
IR 567038 -Actions initiated by the corrective  
IR 567038 - Actions initiated  
action program have resulted in  
by the corrective action
identifying  
program have resulted in  
adverse trends on  
identifying adverse trends on  
[electromagnetic relief valve]  
[electromagnetic relief valve]  
EMRV instruments.  
EMRV instruments. Actions
Actions initiated by the [corrective  
initiated by the [corrective  
actions] have resulted in  
actions] have resulted in  
implementing  
implementing replacement of
replacement  
the pressure switches and  
of the pressure switches and control relays and  
control relays and  
establishing  
establishing routine
routine replacement  
replacement [preventative  
[preventative  
maintenance] tasks.  
maintenance]  
4  
tasks. 4 Source: 3/28/05 letter 20040, Page 1  
Source: 3/28/05  
of attachment. Item listed (ML0509042340) To ensure that the  
letter 2130-05
Standby Liquid Control system is initiated in the event of a [large break] LOCA, the  
20040, Page 1  
Oyster Creek [EOPs] will be revised as required. Within 90 days of NRC issuance of license amendment.  
of attachment.  
Item listed  
(ML0509042340)  
To ensure that the Standby Liquid Control system is  
initiated in the event of a [large break] LOCA, the Oyster
Creek [EOPs] will be revised as required.  
Within 90 days  
of NRC  
issuance of  
license  
amendment.  
Procedures  
Procedures  
EMG-SP7, 3200.01 (refer also to Item 1)  
EMG-SP7, 2000-GLN
3200.01  
(refer also to Item 1)  
RCMT 189765-48  
RCMT 189765-48  
Table 1
Table 1  
-7 Item Source Commitment  
 
- 7  
Item  
Source  
Commitment  
Timeframe  
Timeframe  
Comments 5 Source: 3/31/05 letter 20062, Attachment  
Comments  
2. Second item. (ML0509600680) Revise the  
5  
administrative  
Source: 3/31/05  
procedure for control  
letter 2130-05
of EOP documents (CC-AA-309, Control of Design  
20062,  
Analysis)  
Attachment 2.  
to include instructions to use the  
Second item.  
appropriate  
(ML0509600680)  
configuration control process to revise the plant  
Revise the administrative procedure for control of EOP  
specific technical  
documents (CC-AA-309, Control of Design Analysis) to
include instructions to use the appropriate configuration
control process to revise the plant specific technical  
guidelines (PSTG) Appendix C criteria.  
guidelines (PSTG) Appendix C criteria.  
CAP 1986-12 was  
CAP 02004
completed  
1986-12 was  
on 12/02/2004  
completed on
AD-OC-103, "EOP/SAM [severe accident mitigation] Program Control," includes  
12/02/2004  
AD-OC-103, "EOP/SAM  
[severe accident mitigation]  
Program Control," includes  
annotations associated with  
annotations associated with  
the implementation of this commitment.  
the implementation of this  
* Section 6.5.2 -CM-2, LAR 05012.02, Nov  
commitment.  
04-213 (Steps 4.1.3.13, 4.1.3.14).  
*  
* Section 4.1.3.13 -Any change to a design input, setpoint, used in  
Section 6.5.2 - CM-2,  
Appendix C to the PSTGs shall be  
LAR 05012.02, Nov EA
controlled  
04-213 (Steps 4.1.3.13,  
in accordance with CC-AA-102, "Design Input and  
4.1.3.14).  
Configuration  
*  
Change Impact Screening.  
Section 4.1.3.13 - Any  
2) * Section 4.1.3.14 -All changes to the calculations  
change to a design  
in Appendix C to the PSTGs shall be  
input, setpoint, used in  
controlled  
Appendix C to the  
in accordance with Procedure 309, "Control of Design  
PSTGs shall be  
Analyses." (CM-2) RCMT 620989-05  
controlled in accordance  
Table 1
with CC-AA-102,  
-8 Item Source Commitment  
"Design Input and  
Configuration Change
Impact Screening. (CM
2)  
*  
Section 4.1.3.14 - All  
changes to the  
calculations in Appendix  
C to the PSTGs shall be  
controlled in accordance  
with Procedure CC-AA
309, "Control of Design  
Analyses." (CM-2)  
RCMT  
620989-05  
Table 1  
 
- 8  
Item Source  
Commitment  
Timeframe  
Timeframe  
Comments 6 Source: Attachment 3 of Self-Assessment. Page 7, second and third  
Comments  
DC items and Page 10 -DC items. Page 7 * Verification of  
6  
proper annotation of  
Source:  
current commitments using  
Attachment 3 of  
PassPort after data transfer.  
Self-
Assessment.  
Page 7, second  
and third DC
items and Page  
10 - DC items.  
Page 7  
* Verification of proper annotation of current
commitments using PassPort after data transfer.  
(487012-10)  
(487012-10)  
* Transfer of data to  
* Transfer of data to PassPort and train site on proper
PassPort and train site on  
commitment management. (487012-10)  
proper commitment  
Page 10  
management.  
* Lotus Notes Database currently not site-wide  
(487012-10) Page 10 * Lotus Notes  
searchable and known commitments may be missed.  
Database currently not site-wide searchable and known  
(IR 380386)  
commitments may be missed. (IR 380386)  
Actions  
Actions Completed  
Completed  
IR 487012-10 (references  
IR  
487012-10  
(references  
IR 528865-48)  
IR 528865-48)  
IR 380386 -01,02,03,04, and 05 Internal actions completed as a result of  
IR  
self-assessment  
380386 -01,02,03,04, and  
7 Commitment  
05  
Change Evaluation  
Internal actions completed as  
Forms. * Commitment  
a result of self-assessment  
Tracking Numbers 08-006, R1,08-002  
7  
Commitment  
Change  
Evaluation  
Forms.  
* Commitment Tracking Numbers 08-006, 08-004
R1,08-002  
Procedural  
Procedural  
requirements  
requirements  
completed  
completed  
Attachment 1 from 110 Commitment  
Attachment 1 from LS-AA
changes requiring both the need to inform and not inform NRC  
110  
Table 1
Commitment changes
Mr. Charles G. Pardee President and  
requiring both the need to  
Chief Nuclear Officer Exelon Generation  
inform and not inform NRC  
Company 4300 Winfield Road Warrenville, IL 60555 OYSTER CREEK NUCLEAR GENERATING  
Table 1  
STATION (OCNGS) -AUDIT OF EXELON'S MANAGEMENT  
 
OF REGULATORY  
Mr. Charles G. Pardee  
COMMITMENTS (TAC NO. ME0362) Dear Mr. Pardee: In Regulatory Issue  
President and Chief Nuclear Officer  
Summary 2000-17, "Managing  
Exelon Generation Company
Regulatory  
4300 Winfield Road  
Commitments Made by Power  
Warrenville, IL 60555  
Reactor Licensees to the NRC Staff," dated  
SUB~IECT 
September  
OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF  
21,2000, the U. S.  
EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.  
Nuclear Regulatory  
ME0362)  
Commission (NRC) informed  
Dear Mr. Pardee:  
licensees that the Nuclear Energy Institute  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power  
document NEI 99-04, "Guidelines  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory  
for Managing NRC Commitment  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,  
Changes," contains acceptable  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for  
guidance for controlling regulatory  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or  
commitments  
similar administrative controls to ensure that regulatory commitments are implemented and that  
and encouraged licensees to use the NEI  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the  
guidance or similar administrative  
NRC.  
controls to ensure that regulatory  
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of  
commitments are implemented and that  
licensees' commitment management programs once every 3 years to determine whether the  
changes to the regulatory  
licensees' programs are consistent with the industry gUidance in NEI 99-04, and that regulatory  
commitments are evaluated and, when  
commitments are being effectively implemented.  
appropriate, reported to the  
An audit of OCNGS's commitment management program was performed during January and  
NRC. The NRC Office of  
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,  
Nuclear Reactor Regulation has instructed its  
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
staff to perform an audit of  
acceptable program for implementing and managing NRC commitments. Details of the audit  
licensees'  
are set forth in the enclosed audit report.  
commitment  
Sincerely,  
management programs once every 3 years to  
G. Edward Miller, Project Manager
determine  
Plant Licensing Branch 1-2  
whether the licensees'  
Division of Operating Reactor Licensing  
programs are consistent with the industry gUidance in NEI 99-04, and that regulatory  
Office of Nuclear Reactor Regulation  
commitments are being  
Docket No. 50-219  
effectively  
Enclosure: Audit Report  
implemented. An audit of  
cc w/encl: Distribution via ListServ  
OCNGS's commitment  
DISTRIBUTION:  
management program was  
Public  
performed during January and February 2009, including  
LPL1-2 Reading Resource
activities at Exelon's office in Kennett Square, PA on February 24, 2009. The NRC  
RidsAcrsAcnw_MailCTR Resource  
staff concludes, based on the audit, that OCNGS has  
RidsNrrDorlLpl1-2 Resource
implemented  
RidsNrrPMEMiller Resource  
an acceptable program for  
RidsNrrLAABaxter Resource  
implementing and managing NRC  
RidsOgc Resource  
commitments. Details of the audit are set forth in the  
RidsRgn1MailCenter Resource
enclosed audit report.  
RidsNrrDorlDpr Resource  
Sincerely, G. Edward Miller, Project  
ACCESSION No'.. ML090570036  
Manager Plant Licensing Branch  
NRR-106  
1-2 Division of Operating  
* via email  
Reactor Licensing Office of  
OFFICE  
Nuclear Reactor Regulation Docket No. 50-219  
LPLI-2\\PM  
Enclosure:  
LPLI-2\\PM  
Audit Report cc w/encl: Distribution  
LPLI-2\\LA  
via ListServ DISTRIBUTION:  
LPLI-2\\BC  
Public LPL1-2 Reading  
NAME  
Resource RidsAcrsAcnw_MailCTR
GMiller  
Resource RidsNrrDorlLpl1-2  
DEgan  
Resource RidsNrrPMEMiller
ABaxter  
Resource RidsNrrLAABaxter
HChernoff  
Resource RidsOgc Resource  
DATE  
RidsRgn1 MailCenter
2/27109  
Resource RidsNrrDorlDpr
02/26/09  
Resource ACCESSION  
02/27/09*  
No'.. ML090570036 NRR-106 * via email  
2/27109  
OFFICE LPLI-2\PM  
OFFICIAL RECORD COPY
LPLI-2\PM  
LPLI-2\LA  
LPLI-2\BC  
NAME GMiller DEgan ABaxter HChernoff  
DATE 2/27109 02/26/09 02/27/09*  
2/27109 OFFICIAL RECORD
}}
}}

Latest revision as of 13:03, 14 January 2025

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


See also: RIS 2000-17

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

February 27, 2009

Mr. Charles G. Pardee

President and Chief Nuclear Officer

Exelon Generation Company

4300 Winfield Road

Warrenville, IL 60555

SUB..IECT

OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF

EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.

ME0362)

Dear Mr. Pardee:

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

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

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

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

controlling regulatory commitments and encouraged licensees to use the NEI guidance or

similar administrative controls to ensure that regulatory commitments are implemented and that

changes to the regulatory commitments are evaluated and, when appropriate, reported to the

NRC.

The NRC Office of Nuclear Reactor Requtation has instructed its staff to perform an audit of

licensees' commitment management programs once every 3 years to determine whether the

licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory

commitments are being effectively implemented.

An audit of OCNGS's commitment management program was performed during January and

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

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

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

are set forth in the enclosed audit report.

G. dward Miller, Project Man ger

Plant Licensing Branch 1-2

Division of Operating Reactor Licensing

Office of Nuclear Reactor Regulation

Docket No. 50-219

Enclosure: Audit Report

cc w/encl: Distribution via ListServ

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION

LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS

OYSTER CREEK NUCLEAR GENERATING STATION

DOCKET NO. 50-219

1.0

INTRODUCTION AND BACKGROUND

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

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

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

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

controlling regulatory commitments and encouraged licensees to use the NEI guidance or

similar administrative controls to ensure that regulatory commitments are implemented and that

changes to the regulatory commitments are evaluated and, when appropriate, reported to the

NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit

of licensees' commitment management programs once every 3 years to determine whether the

licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory

commitments are being effectively implemented.

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

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

NRR guidelines direct the NRR Project Manager to audit the licensee's commitment

management program by assessing the adequacy of the licensee's implementation of a sample

of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions,

etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0

AUDIT PROCEDURE AND RESULTS

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

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

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

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

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

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

managing changes to NRC commitments.

Enclosure

- 2

2.1

Verification of Licensee's Implementation of NRC Commitments

The primary focus of this part of the audit is to confirm that the licensee has implemented

commitments made to the NRC as part of past licensing actions/activities. For commitments not

yet implemented, the NRC staff determines whether they have been captured in an effective

program for future implementation.

2.1.1 Audit Scope

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

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

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

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

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

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

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

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

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

(1)

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

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

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

process.)

(2)

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

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

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

completed.

(3)

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

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

safety analysis reports. Fulfillment of these commitments was indicated by the licensee

having taken timely action in accordance with the subject requirements.

2.1.2

Audit Results

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

audit.

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

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

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

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

result of commitments made by the licensee to NRC.

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

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

- 3

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

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

corrective actions were initiated.

2.2

Verification of the Licensee's Program for Managing NRC Commitment Changes

The primary focus of this part of the audit is to verify that the licensee has established

administrative controls for modifying or deleting commitments made to the NRC. The NRC staff

compared the licensee's process for controlling regulatory commitments to the guidelines in

NEI-99-04, which the NRC has found to be an acceptable guide for licensees to follow for

managing and changing commitments. The process used at OCNGS is contained in LS-AA

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

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

not or will not be reported to the NRC. The audit also verifies that the licensee's commitment

management system includes a mechanism to ensure traceability of commitments following

initial implementation. This ensures that licensee personnel are able to recognize that future

proposed changes to the affected design features or operating practices require evaluation in

accordance with the commitment change control process.

2.2.1

Audit Results

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

audit.

The NRC staff reviewed the licensee's procedure LS-AA-110, Revision 6,. Section 6.1 of the

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

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

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

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

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

attributes for an acceptable commitment management program.

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

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

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

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

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

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

addressed verification of proper annotation after the transfer. Related procedure

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

was also reviewed.

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

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

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

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

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

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

- 4

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

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

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

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

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

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

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

extended implications.

3.0

CONCLUSION

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

provides the necessary attributes for an acceptable commitment management program.

4.0

LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT

Richard Gropp

Calvin Taylor

John Hufnagel

Pam Cowan

Principal Contributor: D. Egan

- 5

Item

Source

Commitment

Timeframe

Comments

1

Source: 1/24/07

letter 2130-07

20448,

Summary of

Commitments.

Second item.

(ML07031 01010)

Oyster Creek [emergency operations procedure] EOP

Support Procedure 7 will be revised to direct the

Operator to inject the entire contents of the Liquid Poison

tank in the event that a [loss of coolant accident] LOCA is

in progress. Include these EOP changes and their basis

in Licensed Operator Training, and update the EOP

User's Guide to include the use of sodium pentaborate

for pH control of the suppression pool under LOCA

conditions.

Upon

implementation

of approved

amendment.

Procedure

EMG-SP7 - not annotated

(revised parent document

annotated)

RCMT 189765-48

2

Source: 7/3/08

letter RA-08

060, Attachment

2. First item on

page 9 and last

item on page 10.

(ML0819308020)

First item on page 9: Oyster Creek will follow the

guidelines in Section 11.3.6.5 of NUMARC 93-01, Rev. 3

during refueling within containment. Plant procedures

will be revised, as appropriate, to implement these

guidelines.

Last item on oaae 10: The following secondary

containment potential openings will remain closed during

refueling activities under administrative controls:

Ventilation ductwork below siding structure on

west side of Reactor Building (north end of west

wall)

Ventilation ductwork below siding structure on

west side of Reactor Building (south end of west

wall)

Trunion Room Doors to Turbine Building

Reactor Building Commodities (flanged)

penetration on north RB wall

MAC Facility Doors

Upon

implementation

of approved

amendment.

Note: This

License

Amendment

Request has

not been

approved.

The commitments associated

with License Amendment

Request are being tracked

under Passport Action

Requests 642132 and

828005.

This issue is still under review

by the NRC. The

commitments associated with

this License Amendment

Request will be implemented

as approved by the NRC.

Table 1

- 6

Item Source

Commitment

Timeframe

Comments

3

Source; 2/2/07

letter 2130-07

20450, Page 4.

Corrective

action planned

item.

(ML0703803170)

The new pressure switch performance will be monitored

for a year to determine if periodic replacement of the

pressure switches is warranted.

One year after

[license event

report] LER

submittal.

IR 567038 - Actions initiated

by the corrective action

program have resulted in

identifying adverse trends on

[electromagnetic relief valve]

EMRV instruments. Actions

initiated by the [corrective

actions] have resulted in

implementing replacement of

the pressure switches and

control relays and

establishing routine

replacement [preventative

maintenance] tasks.

4

Source: 3/28/05

letter 2130-05

20040, Page 1

of attachment.

Item listed

(ML0509042340)

To ensure that the Standby Liquid Control system is

initiated in the event of a [large break] LOCA, the Oyster

Creek [EOPs] will be revised as required.

Within 90 days

of NRC

issuance of

license

amendment.

Procedures

EMG-SP7, 2000-GLN

3200.01

(refer also to Item 1)

RCMT 189765-48

Table 1

- 7

Item

Source

Commitment

Timeframe

Comments

5

Source: 3/31/05

letter 2130-05

20062,

Attachment 2.

Second item.

(ML0509600680)

Revise the administrative procedure for control of EOP

documents (CC-AA-309, Control of Design Analysis) to

include instructions to use the appropriate configuration

control process to revise the plant specific technical

guidelines (PSTG) Appendix C criteria.

CAP 02004

1986-12 was

completed on

12/02/2004

AD-OC-103, "EOP/SAM

[severe accident mitigation]

Program Control," includes

annotations associated with

the implementation of this

commitment.

Section 6.5.2 - CM-2,

LAR 05012.02, Nov EA

04-213 (Steps 4.1.3.13,

4.1.3.14).

Section 4.1.3.13 - Any

change to a design

input, setpoint, used in

Appendix C to the

PSTGs shall be

controlled in accordance

with CC-AA-102,

"Design Input and

Configuration Change

Impact Screening. (CM

2)

Section 4.1.3.14 - All

changes to the

calculations in Appendix

C to the PSTGs shall be

controlled in accordance

with Procedure CC-AA

309, "Control of Design

Analyses." (CM-2)

RCMT

620989-05

Table 1

- 8

Item Source

Commitment

Timeframe

Comments

6

Source:

Attachment 3 of

Self-

Assessment.

Page 7, second

and third DC

items and Page

10 - DC items.

Page 7

  • Verification of proper annotation of current

commitments using PassPort after data transfer.

(487012-10)

  • Transfer of data to PassPort and train site on proper

commitment management. (487012-10)

Page 10

  • Lotus Notes Database currently not site-wide

searchable and known commitments may be missed.

(IR 380386)

Actions

Completed

IR

487012-10

(references

IR 528865-48)

IR

380386 -01,02,03,04, and

05

Internal actions completed as

a result of self-assessment

7

Commitment

Change

Evaluation

Forms.

  • Commitment Tracking Numbers08-006, 08-004

R1,08-002

Procedural

requirements

completed

Attachment 1 from LS-AA

110

Commitment changes

requiring both the need to

inform and not inform NRC

Table 1

Mr. Charles G. Pardee

President and Chief Nuclear Officer

Exelon Generation Company

4300 Winfield Road

Warrenville, IL 60555

SUB~IECT

OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF

EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.

ME0362)

Dear Mr. Pardee:

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

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

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

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

controlling regulatory commitments and encouraged licensees to use the NEI guidance or

similar administrative controls to ensure that regulatory commitments are implemented and that

changes to the regulatory commitments are evaluated and, when appropriate, reported to the

NRC.

The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of

licensees' commitment management programs once every 3 years to determine whether the

licensees' programs are consistent with the industry gUidance in NEI 99-04, and that regulatory

commitments are being effectively implemented.

An audit of OCNGS's commitment management program was performed during January and

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

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

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

are set forth in the enclosed audit report.

Sincerely,

G. Edward Miller, Project Manager

Plant Licensing Branch 1-2

Division of Operating Reactor Licensing

Office of Nuclear Reactor Regulation

Docket No. 50-219

Enclosure: Audit Report

cc w/encl: Distribution via ListServ

DISTRIBUTION:

Public

LPL1-2 Reading Resource

RidsAcrsAcnw_MailCTR Resource

RidsNrrDorlLpl1-2 Resource

RidsNrrPMEMiller Resource

RidsNrrLAABaxter Resource

RidsOgc Resource

RidsRgn1MailCenter Resource

RidsNrrDorlDpr Resource

ACCESSION No'.. ML090570036

NRR-106

  • via email

OFFICE

LPLI-2\\PM

LPLI-2\\PM

LPLI-2\\LA

LPLI-2\\BC

NAME

GMiller

DEgan

ABaxter

HChernoff

DATE

2/27109

02/26/09

02/27/09*

2/27109

OFFICIAL RECORD COPY

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