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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
| author name = Miller G
| author affiliation = NRC/NRR/DORL/LPLI-2
| author affiliation = NRC/NRR/DORL/LPLI-2
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES
                              NUCLEAR REGULATORY COMMISSION
NUCLEAR REGULATORY COMMISSION
                                      WASHINGTON, D.C. 20555-0001
WASHINGTON, D.C. 20555-0001  
                                            February 27, 2009
February 27, 2009  
Mr. Charles G. Pardee
Mr. Charles G. Pardee  
President and Chief Nuclear Officer
President and Chief Nuclear Officer  
Exelon Generation Company
Exelon Generation Company  
4300 Winfield Road
4300 Winfield Road  
Warrenville, IL 60555
Warrenville, IL 60555  
SUB..IECT       OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF
SUB..IECT
                EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.
OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF  
                ME0362)
EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.  
Dear Mr. Pardee:
ME0362)  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power
Dear Mr. Pardee:  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for  
similar administrative controls to ensure that regulatory commitments are implemented and that
controlling regulatory commitments and encouraged licensees to use the NEI guidance or  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the
similar administrative controls to ensure that regulatory commitments are implemented and that  
NRC.
changes to the regulatory commitments are evaluated and, when appropriate, reported to the  
The NRC Office of Nuclear Reactor Requtation has instructed its staff to perform an audit of
NRC.  
licensees' commitment management programs once every 3 years to determine whether the
The NRC Office of Nuclear Reactor Requtation has instructed its staff to perform an audit of  
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory
licensees' commitment management programs once every 3 years to determine whether the  
commitments are being effectively implemented.
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory  
An audit of OCNGS's commitment management program was performed during January and
commitments are being effectively implemented.  
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,
An audit of OCNGS's commitment management program was performed during January and  
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,  
acceptable program for implementing and managing NRC commitments. Details of the audit
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an  
are set forth in the enclosed audit report.
acceptable program for implementing and managing NRC commitments. Details of the audit  
                                              G. dward Miller, Project Man ger
are set forth in the enclosed audit report.  
                                              Plant Licensing Branch 1-2
G. dward Miller, Project Man ger  
                                              Division of Operating Reactor Licensing
Plant Licensing Branch 1-2  
                                              Office of Nuclear Reactor Regulation
Division of Operating Reactor Licensing  
Docket No. 50-219
Office of Nuclear Reactor Regulation  
Enclosure: Audit Report
Docket No. 50-219  
cc w/encl: Distribution via ListServ
Enclosure: Audit Report  
cc w/encl: Distribution via ListServ  


                                                UNITED STATES
UNITED STATES
                                NUCLEAR REGULATORY COMMISSION
NUCLEAR REGULATORY COMMISSION
                                          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 OF REGULATORY COMMITMENTS
LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS  
                      OYSTER CREEK NUCLEAR GENERATING STATION
OYSTER CREEK NUCLEAR GENERATING STATION  
                                          DOCKET NO. 50-219
DOCKET NO. 50-219  
1.0     INTRODUCTION AND BACKGROUND
1.0  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power
INTRODUCTION AND BACKGROUND  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for  
similar administrative controls to ensure that regulatory commitments are implemented and that
controlling regulatory commitments and encouraged licensees to use the NEI guidance or  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the
similar administrative controls to ensure that regulatory commitments are implemented and that  
NRC.
changes to the regulatory commitments are evaluated and, when appropriate, reported to the  
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit
NRC.  
of licensees' commitment management programs once every 3 years to determine whether the
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit  
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory
of licensees' commitment management programs once every 3 years to determine whether the  
commitments are being effectively implemented.
licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory  
NEI-99-04 defines a "regulatory commitment" as an explicit statement to take a specific action
commitments are being effectively implemented.  
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  
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment
agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.  
management program by assessing the adequacy of the licensee's implementation of a sample
NRR guidelines direct the NRR Project Manager to audit the licensee's commitment  
of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions,
management program by assessing the adequacy of the licensee's implementation of a sample  
etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions,  
2.0     AUDIT PROCEDURE AND RESULTS
etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.  
An audit of the Oyster Creek Nuclear Generating Station (OCNGS) commitment management
2.0  
program was performed at the NRC Headquarters using documentation provided by the
AUDIT PROCEDURE AND RESULTS  
licensee and at the licensee's Kennett Square office during the period of January and February
An audit of the Oyster Creek Nuclear Generating Station (OCNGS) commitment management  
2009. The audit reviewed commitments made since the previous audit in January 2004. The
program was performed at the NRC Headquarters using documentation provided by the  
audit consisted of two major parts: (1) verification of the licensee's implementation of NRC
licensee and at the licensee's Kennett Square office during the period of January and February  
commitments that have been completed, and (2) verification of the licensee's program for
2009. The audit reviewed commitments made since the previous audit in January 2004. The  
managing changes to NRC commitments.
audit consisted of two major parts: (1) verification of the licensee's implementation of NRC  
                                                                                            Enclosure
commitments that have been completed, and (2) verification of the licensee's program for  
managing changes to NRC commitments.  
Enclosure  


                                                  -2
- 2  
2.1     Verification of Licensee's Implementation of NRC Commitments
2.1
The primary focus of this part of the audit is to confirm that the licensee has implemented
Verification of Licensee's Implementation of NRC Commitments  
commitments made to the NRC as part of past licensing actions/activities. For commitments not
The primary focus of this part of the audit is to confirm that the licensee has implemented  
yet implemented, the NRC staff determines whether they have been captured in an effective
commitments made to the NRC as part of past licensing actions/activities. For commitments not  
program for future implementation.
yet implemented, the NRC staff determines whether they have been captured in an effective  
2.1.1   Audit Scope
program for future implementation.  
The audit addressed a sample of commitments made during the review period. The audit
2.1.1 Audit Scope  
focused on regulatory commitments (as defined above) made in writing to the NRC as a result
The audit addressed a sample of commitments made during the review period. The audit  
of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins,
focused on regulatory commitments (as defined above) made in writing to the NRC as a result  
generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices
of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins,  
of Violation may be included in the sample, but the review will be limited to verification of
generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices  
restoration of compliance, not the specific methods used. Before the audit, the NRC staff
of Violation may be included in the sample, but the review will be limited to verification of  
searched the Agencywide Documents Access and Management System (ADAMS) for the
restoration of compliance, not the specific methods used. Before the audit, the NRC staff  
licensee's submittals since the last audit and selected a representative sample for verification.
searched the Agencywide Documents Access and Management System (ADAMS) for the  
The audit excluded the following types of commitments that are internal to licensee processes:
licensee's submittals since the last audit and selected a representative sample for verification.  
(1)     Commitments made on the licensee's own initiative among internal organizational
The audit excluded the following types of commitments that are internal to licensee processes:  
        components. (Note: the internal self-assessment and subsequent transition to the
(1)
        Exelon Passport program was audited as an indicator of the commitment to the
Commitments made on the licensee's own initiative among internal organizational  
        process.)
components. (Note: the internal self-assessment and subsequent transition to the  
(2)     Commitments that pertain to milestones of licensing actions/activities (e.g., respond to
Exelon Passport program was audited as an indicator of the commitment to the  
        an NRC request for additional information by a certain date). Fulfillment of these
process.)  
        commitments was indicated by the fact that the subject licensing action/activity was
(2)
        completed.
Commitments that pertain to milestones of licensing actions/activities (e.g., respond to  
(3)     Commitments made as an internal reminder to take actions to comply with existing
an NRC request for additional information by a certain date). Fulfillment of these  
        regulatory requirements such as regulations, technical specifications, and updated final
commitments was indicated by the fact that the subject licensing action/activity was  
        safety analysis reports. Fulfillment of these commitments was indicated by the licensee
completed.  
        having taken timely action in accordance with the subject requirements.
(3)
2.1.2   Audit Results
Commitments made as an internal reminder to take actions to comply with existing  
Table 1 contains a list of those documents that were selected for additional review during this
regulatory requirements such as regulations, technical specifications, and updated final  
audit.
safety analysis reports. Fulfillment of these commitments was indicated by the licensee  
The NRC staff found that the licensee's commitment tracking program had captured all the
having taken timely action in accordance with the subject requirements.  
regulatory commitments that were identified by the NRC staff before the audit. The NRC staff
2.1.2
also reviewed plant procedures, assessment recommendations, work orders, corrective actions,
Audit Results  
training, qualification certifications and action requests that had been initiated or revised as a
Table 1 contains a list of those documents that were selected for additional review during this  
result of commitments made by the licensee to NRC.
audit.  
The program has a requirement that the licensee perform an annual review and assessment of
The NRC staff found that the licensee's commitment tracking program had captured all the  
site and corporate commitments. The most recent OCNGS annual review was reviewed by 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
- 3
NRC staff. The annual review appeared thorough, addressing over 300 items. It identified
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
isolated concerns with procedure annotation. Further, the NRC staff found that appropriate  
corrective actions were initiated.
corrective actions were initiated.  
2.2     Verification of the Licensee's Program for Managing NRC Commitment Changes
2.2  
The primary focus of this part of the audit is to verify that the licensee has established
Verification of the Licensee's Program for Managing NRC Commitment Changes  
administrative controls for modifying or deleting commitments made to the NRC. The NRC staff
The primary focus of this part of the audit is to verify that the licensee has established  
compared the licensee's process for controlling regulatory commitments to the guidelines in
administrative controls for modifying or deleting commitments made to the NRC. The NRC staff  
NEI-99-04, which the NRC has found to be an acceptable guide for licensees to follow for
compared the licensee's process for controlling regulatory commitments to the guidelines in  
managing and changing commitments. The process used at OCNGS is contained in LS-AA
NEI-99-04, which the NRC has found to be an acceptable guide for licensees to follow for  
110 - Revision 6, "Commitment Management." The audit reviewed a sample of commitment
managing and changing commitments. The process used at OCNGS is contained in LS-AA
changes that included changes that were or will be reported to the NRC, and changes that were
110 - Revision 6, "Commitment Management." The audit reviewed a sample of commitment  
not or will not be reported to the NRC. The audit also verifies that the licensee's commitment
changes that included changes that were or will be reported to the NRC, and changes that were  
management system includes a mechanism to ensure traceability of commitments following
not or will not be reported to the NRC. The audit also verifies that the licensee's commitment  
initial implementation. This ensures that licensee personnel are able to recognize that future
management system includes a mechanism to ensure traceability of commitments following  
proposed changes to the affected design features or operating practices require evaluation in
initial implementation. This ensures that licensee personnel are able to recognize that future  
accordance with the commitment change control process.
proposed changes to the affected design features or operating practices require evaluation in  
2.2.1     Audit Results
accordance with the commitment change control process.  
Table 1 contains a list of those documents that were selected for additional review during this
2.2.1  
audit.
Audit Results  
The NRC staff reviewed the licensee's procedure LS-AA-11 0, Revision 6,. Section 6.1 of the
Table 1 contains a list of those documents that were selected for additional review during this  
procedure lists NEI 99-04 as a reference. The NRC staff found that LS-AA-11 0 generally
audit.  
follows the guidance of NEI 99-04 and provides detailed instructions for making regulatory
The NRC staff reviewed the licensee's procedure LS-AA-110, Revision 6,. Section 6.1 of the  
commitments, tracking regulatory commitments, annotating documents to provide traceability of
procedure lists NEI 99-04 as a reference. The NRC staff found that LS-AA-11 0 generally  
commitments, and for making changes to commitments. Therefore, the NRC staff concludes
follows the guidance of NEI 99-04 and provides detailed instructions for making regulatory  
that the procedure used by the licensee to manage commitments provides the necessary
commitments, tracking regulatory commitments, annotating documents to provide traceability of  
attributes for an acceptable commitment management program.
commitments, and for making changes to commitments. Therefore, the NRC staff concludes  
The NRC Staff noted that a self-assessment had been performed since the last NRC audit and
that the procedure used by the licensee to manage commitments provides the necessary  
the potential concern identified in the previous NRC audit about the use of multiple commitment
attributes for an acceptable commitment management program.  
tracking systems was addressed. Three recommendations from the self-assessment were
The NRC Staff noted that a self-assessment had been performed since the last NRC audit and  
entered into the commitment tracking program and acted upon. One of the recommendations
the potential concern identified in the previous NRC audit about the use of multiple commitment  
that OCNGS transition to the Passport tracking program (Exelon fleet-wide system) from the
tracking systems was addressed. Three recommendations from the self-assessment were  
use of multiple programs addressed the previous potential concern. Another recommendation
entered into the commitment tracking program and acted upon. One of the recommendations  
addressed verification of proper annotation after the transfer. Related procedure
that OCNGS transition to the Passport tracking program (Exelon fleet-wide system) from the  
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport,"
use of multiple programs addressed the previous potential concern. Another recommendation  
was also reviewed.
addressed verification of proper annotation after the transfer. Related procedure  
The NRC staff also reviewed documents that had been created or revised as a result of
LS-AA-110-1001, Revision 4, "Commitment Tracking Program T&RM for Use with Passport,"  
commitments made by the licensee to the NRC. The staff noted that, except as noted below,
was also reviewed.  
the revised documents have annotations referring to commitments as part of the commitment
The NRC staff also reviewed documents that had been created or revised as a result of  
change control process. These annotations serve to prevent the commitments from
commitments made by the licensee to the NRC. The staff noted that, except as noted below,  
inadvertently being deleted or altered without having gone through the commitment change
the revised documents have annotations referring to commitments as part of the commitment  
process. The NRC observed that in response to one commitment (Item 1 in Table 1)
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
- 4
emergency procedures were revised, an operations briefing developed and the training program
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
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)
(Plant Specific Technical Guidelines for the Symptom Based Emergency Operating Procedures)  
was annotated consistent with the procedural requirements. However, the "EOP Support
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
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
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
action program to evaluate the annotation requirements and determine if there are any  
extended implications.
extended implications.  
3.0     CONCLUSION
3.0  
As discussed above, the licensee's procedure used to implement and manage commitments
CONCLUSION  
provides the necessary attributes for an acceptable commitment management program.
As discussed above, the licensee's procedure used to implement and manage commitments  
4.0     LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
provides the necessary attributes for an acceptable commitment management program.  
Richard Gropp
4.0  
Calvin Taylor
LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT  
John Hufnagel
Richard Gropp  
Pam Cowan
Calvin Taylor  
Principal Contributor: D. Egan
John Hufnagel  
Pam Cowan  
Principal Contributor: D. Egan  


                                                              - 5
- 5
Item Source           Commitment                                                 Timeframe     Comments
Item  
    Source: 1/24/07 Oyster Creek [emergency operations procedure] EOP           Upon          Procedure
Source  
  1  letter 2130-07  Support Procedure 7 will be revised to direct the           implementation EMG-SP7 - not annotated
Commitment  
    20448,          Operator to inject the entire contents of the Liquid Poison of approved
Timeframe  
    Summary of      tank in the event that a [loss of coolant accident] LOCA is amendment.    (revised parent document
Comments  
    Commitments.    in progress. Include these EOP changes and their basis                     annotated)
1
    Second item.    in Licensed Operator Training, and update the EOP
Source: 1/24/07  
    (ML07031 0101 0) User's Guide to include the use of sodium penta borate                    RCMT 189765-48
letter 2130-07
                      for pH control of the suppression pool under LOCA
20448,
                      conditions.
Summary of
    Source: 7/3/08   First item on page 9: Oyster Creek will follow the         Upon          The commitments associated
Commitments.
  2  letter RA-08    guidelines in Section 11.3.6.5 of NUMARC 93-01, Rev. 3     implementation with License Amendment
Second item.
    060, Attachment  during refueling within containment. Plant procedures       of approved    Request are being tracked
(ML07031 01010)
    2. First item on will be revised, as appropriate, to implement these         amendment.    under Passport Action
Oyster Creek [emergency operations procedure] EOP  
    page 9 and last  guidelines.                                                               Requests 642132 and
Support Procedure 7 will be revised to direct the  
    item on page 10.                                                                            828005.
Operator to inject the entire contents of the Liquid Poison  
    (ML0819308020)  Last item on oaae 10: The following secondary               Note: This
tank in the event that a [loss of coolant accident] LOCA is  
                      containment potential openings will remain closed during   License        This issue is still under review
in progress. Include these EOP changes and their basis  
                      refueling activities under administrative controls:         Amendment      by the NRC. The
in Licensed Operator Training, and update the EOP  
                          * Ventilation ductwork below siding structure on       Request has    commitments associated with
User's Guide to include the use of sodium pentaborate
                              west side of Reactor Building (north end of west   not been      this License Amendment
for pH control of the suppression pool under LOCA  
                              wall)                                             approved.      Request will be implemented
conditions.  
                          * Ventilation ductwork below siding structure on                     as approved by the NRC.
Upon
                              west side of Reactor Building (south end of west
implementation
                              wall)
of approved
                          *   Trunion Room Doors to Turbine Building
amendment.
                          * Reactor Building Commodities (flanged)
Procedure
                              penetration on north RB wall
EMG-SP7 - not annotated
                          * MAC Facility Doors
(revised parent document
                                                            Table 1
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
- 6  
Item Source         Commitment                                                 Timeframe     Comments
Item Source  
    Source; 2/2/07 The new pressure switch performance will be monitored     One year after IR 567038 - Actions initiated
Commitment  
  3  letter 2130-07 for a year to determine if periodic replacement of the     [license event by the corrective action
Timeframe  
    20450, Page 4.  pressure switches is warranted.                           report] LER   program have resulted in
Comments  
    Corrective                                                                submittal.    identifying adverse trends on
3
    action planned                                                                            [electromagnetic relief valve]
Source; 2/2/07  
    item.                                                                                    EMRV instruments. Actions
letter 2130-07
    (ML0703803170)                                                                            initiated by the [corrective
20450, Page 4.
                                                                                              actions] have resulted in
Corrective
                                                                                              implementing replacement of
action planned
                                                                                              the pressure switches and
item.
                                                                                              control relays and
(ML0703803170)
                                                                                              establishing routine
The new pressure switch performance will be monitored  
                                                                                              replacement [preventative
for a year to determine if periodic replacement of the  
                                                                                              maintenance] tasks.
pressure switches is warranted.  
    Source: 3/28/05 To ensure that the Standby Liquid Control system is       Within 90 days Procedures
One year after
  4  letter 2130-05 initiated in the event of a [large break] LOCA, the Oyster of NRC        EMG-SP7, 2000-GLN
[license event
    20040, Page 1  Creek [EOPs] will be revised as required.                 issuance of   3200.01
report] LER  
    of attachment.                                                            license
submittal.
    Item listed                                                                amendment.     (refer also to Item 1)
IR 567038 - Actions initiated
    (ML0509042340)
by the corrective action
                                                                                              RCMT 189765-48
program have resulted in  
                                                            Table 1
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
- 7  
Item Source         Commitment                                               Timeframe   Comments
Item  
    Source: 3/31/05 Revise the administrative procedure for control of EOP   CAP 02004  AD-OC-103, "EOP/SAM
Source  
  5  letter 2130-05 documents (CC-AA-309, Control of Design Analysis) to     1986-12 was  [severe accident mitigation]
Commitment  
    20062,          include instructions to use the appropriate configuration completed on Program Control," includes
Timeframe  
    Attachment 2.  control process to revise the plant specific technical   12/02/2004   annotations associated with
Comments  
    Second item.    guidelines (PSTG) Appendix C criteria.                                the implementation of this
5
    (ML0509600680)                                                                        commitment.
Source: 3/31/05  
                                                                                              * Section 6.5.2 - CM-2,
letter 2130-05
                                                                                                LAR 05012.02, Nov EA
20062,
                                                                                                04-213 (Steps 4.1.3.13,
Attachment 2.
                                                                                                4.1.3.14).
Second item.
                                                                                              * Section 4.1.3.13 - Any
(ML0509600680)
                                                                                                change to a design
Revise the administrative procedure for control of EOP  
                                                                                                input, setpoint, used in
documents (CC-AA-309, Control of Design Analysis) to  
                                                                                                Appendix C to the
include instructions to use the appropriate configuration  
                                                                                                PSTGs shall be
control process to revise the plant specific technical  
                                                                                                controlled in accordance
guidelines (PSTG) Appendix C criteria.
                                                                                                with CC-AA-102,
CAP 02004
                                                                                                "Design Input and
1986-12 was
                                                                                                Configuration Change
completed on
                                                                                                  Impact Screening. (CM
12/02/2004  
                                                                                                2)
AD-OC-103, "EOP/SAM
                                                                                              * Section 4.1.3.14 - All
[severe accident mitigation]
                                                                                                changes to the
Program Control," includes
                                                                                                calculations in Appendix
annotations associated with  
                                                                                                C to the PSTGs shall be
the implementation of this  
                                                                                                controlled in accordance
commitment.  
                                                                                                with Procedure CC-AA
*  
                                                                                                309, "Control of Design
Section 6.5.2 - CM-2,  
                                                                                                Analyses." (CM-2)
LAR 05012.02, Nov EA
                                                                                            RCMT
04-213 (Steps 4.1.3.13,  
                                                                                            620989-05
4.1.3.14).  
                                                          Table 1
*  
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
- 8  
Item Source         Commitment                                               Timeframe   Comments
Item Source  
    Source:         Page 7                                                  Actions      IR
Commitment  
  6  Attachment 3 of                                                         Completed    487012-10
Timeframe  
    Self-          * Verification of proper annotation of current                       (references
Comments  
    Assessment.        commitments using PassPort after data transfer.                   IR 528865-48)
6
    Page 7, second    (487012-10)
Source:  
    and third DC                                                                          IR
Attachment 3 of  
    items and Page  * Transfer of data to PassPort and train site on proper             380386 -01,02,03,04, and
Self-
    10 - DC items.    commitment management. (487012-10)                                 05
Assessment.
                    Page 10                                                               Internal actions completed as
Page 7, second
                                                                                          a result of self-assessment
and third DC
                    * Lotus Notes Database currently not site-wide
items and Page
                        searchable and known commitments may be missed.
10 - DC items.
                        (IR 380386)
Page 7
    Commitment     * Commitment Tracking Numbers 08-006, 08-004           Procedural   Attachment 1 from LS-AA
* Verification of proper annotation of current  
  7  Change            R1,08-002                                            requirements 110
commitments using PassPort after data transfer.  
    Evaluation                                                              completed
(487012-10)  
    Forms.                                                                                Commitment changes
* Transfer of data to PassPort and train site on proper  
                                                                                          requiring both the need to
commitment management. (487012-10)  
                                                                                          inform and not inform NRC
Page 10  
                                                          Table 1
* Lotus Notes Database currently not site-wide  
searchable and known commitments may be missed.  
(IR 380386)  
Actions
Completed
IR
487012-10
(references
IR 528865-48)
IR
380386 -01,02,03,04, and
05
Internal actions completed as
a result of self-assessment
7
Commitment  
Change
Evaluation
Forms.
* Commitment Tracking Numbers 08-006, 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
Mr. Charles G. Pardee  
President and Chief Nuclear Officer
President and Chief Nuclear Officer  
Exelon Generation Company
Exelon Generation Company  
4300 Winfield Road
4300 Winfield Road  
Warrenville, IL 60555
Warrenville, IL 60555  
SUB~IECT         OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF
SUB~IECT
                EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.
OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS) - AUDIT OF  
                ME0362)
EXELON'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.  
Dear Mr. Pardee:
ME0362)  
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power
Dear Mr. Pardee:  
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory
In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power  
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,
Reactor Licensees to the NRC Staff," dated September 21,2000, the U. S. Nuclear Regulatory  
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for
Commission (NRC) informed licensees that the Nuclear Energy Institute document NEI 99-04,  
controlling regulatory commitments and encouraged licensees to use the NEI guidance or
"Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for  
similar administrative controls to ensure that regulatory commitments are implemented and that
controlling regulatory commitments and encouraged licensees to use the NEI guidance or  
changes to the regulatory commitments are evaluated and, when appropriate, reported to the
similar administrative controls to ensure that regulatory commitments are implemented and that  
NRC.
changes to the regulatory commitments are evaluated and, when appropriate, reported to the  
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of
NRC.  
licensees' commitment management programs once every 3 years to determine whether the
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of  
licensees' programs are consistent with the industry gUidance in NEI 99-04, and that regulatory
licensees' commitment management programs once every 3 years to determine whether the  
commitments are being effectively implemented.
licensees' programs are consistent with the industry gUidance in NEI 99-04, and that regulatory  
An audit of OCNGS's commitment management program was performed during January and
commitments are being effectively implemented.  
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,
An audit of OCNGS's commitment management program was performed during January and  
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an
February 2009, including activities at Exelon's office in Kennett Square, PA on February 24,  
acceptable program for implementing and managing NRC commitments. Details of the audit
2009. The NRC staff concludes, based on the audit, that OCNGS has implemented an  
are set forth in the enclosed audit report.
acceptable program for implementing and managing NRC commitments. Details of the audit  
                                              Sincerely,
are set forth in the enclosed audit report.  
                                              G. Edward Miller, Project Manager
Sincerely,  
                                              Plant Licensing Branch 1-2
G. Edward Miller, Project Manager  
                                              Division of Operating Reactor Licensing
Plant Licensing Branch 1-2  
                                              Office of Nuclear Reactor Regulation
Division of Operating Reactor Licensing  
Docket No. 50-219
Office of Nuclear Reactor Regulation  
Enclosure: Audit Report
Docket No. 50-219  
cc w/encl: Distribution via ListServ
Enclosure: Audit Report  
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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

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