ML072480261: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(One intermediate revision by the same user not shown)
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:September 18, 2007Mr. James A. Spina, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.
{{#Wiki_filter:September 18, 2007 Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702


==SUBJECT:==
==SUBJECT:==
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDITOF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)                  
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)


==Dear Mr. Spina:==
==Dear Mr. Spina:==


An audit of the commitment management program was performed at the Calvert Cliffs NuclearPower Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes. Details of the audit are described in the enclosed audit report. The NRC staff appreciates theresources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.Sincerely,/RA/Douglas V. Pickett, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-317 and 50-318
An audit of the commitment management program was performed at the Calvert Cliffs Nuclear Power Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes.
Details of the audit are described in the enclosed audit report. The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.
Sincerely,
                                              /RA/
Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318


==Enclosure:==
==Enclosure:==
As statedcc w/encl: See next page September 18, 2007Mr. James A. Spina, Vice PresidentCalvert Cliffs Nuclear Power Plant, Inc.
 
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702
As stated cc w/encl: See next page
 
September 18, 2007 Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.
Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702


==SUBJECT:==
==SUBJECT:==
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDITOF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)                  
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)


==Dear Mr. Spina:==
==Dear Mr. Spina:==


An audit of the commitment management program was performed at the Calvert Cliffs NuclearPower Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes. Details of the audit are described in the enclosed audit report. The NRC staff appreciates theresources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.Sincerely,/RA/Douglas V. Pickett, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-317 and 50-318
An audit of the commitment management program was performed at the Calvert Cliffs Nuclear Power Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes.
Details of the audit are described in the enclosed audit report. The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.
Sincerely,
                                              /RA/
Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318


==Enclosure:==
==Enclosure:==
As statedcc w/encl:  See next page DistributionPUBLICLPL1-1RidsNrrDorlLpl1-1RidsNrrPMDPickettRidsNrrLASLittleRidsOgcRpRidsAcrsAcnwMailCenterRidsRgn1MailCenterAccession: ML072480261OFFICELPLI-1LPLl-1/PMLPLI-1/LALPLI-1/BCNAMEDWoodyattDPickettSLittleMKowalDATE09  /13/  0709  /13/  0709  /12/  0709  /18/  07OFFICIAL RECORD COPY Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:
Mr. Michael J. Wallace, PresidentConstellation Generation Group 750 East Pratt Street Baltimore, MD  21202Mr. John M. HeffleySenior Vice President and Chief Nuclear Officer Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 310 Annapolis, MD  21401PresidentCalvert County Board of Commissioners 175 Main Street Prince Frederick, MD  20678Mr. Carey Fleming, EsquireSr. Counsel - Nuclear Generation Constellation Generation Group, LLC 750 East Pratt Street, 17 th floorBaltimore, MD 21202Mr. Jay S. GainesDirector, Licensing Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD  20657-4702Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD  20685Mr. R. I. McLean, ManagerNuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)
Tawes State Office Building Annapolis, MD 21401Regional Administrator, Region IU.S. Nuclear Regulatory Commission


475 Allendale Road King of Prussia, PA  19406Ms. Kristen A. Burger, EsquireMaryland People's Counsel 6 St. Paul Centre Suite 2102 Baltimore, MD  21202-1631Ms. Patricia T. Birnie, EsquireCo-Director Maryland Safe Energy Coalition P.O. Box 33111 Baltimore, MD  21218Mr. Roy HickokNRC Technical Training Center 5700 Brainerd Road Chattanooga, TN  37411-4017 EnclosureAUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)REGULATORY COMMITMENTS MADE BY THE LICENSEE TOTHE NUCLEAR REGULATORY COMMISSION (NRC)CALVERT CLIFFS NUCLEAR POWER PLANT, INC.CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2DOCKET NOS. 50-317 AND 50-31
As stated cc w/encl: See next page Distribution PUBLIC                  LPL1-1                RidsNrrDorlLpl1-1            RidsNrrPMDPickett RidsNrrLASLittle        RidsOgcRp            RidsAcrsAcnwMailCenter      RidsRgn1MailCenter Accession: ML072480261 OFFICE LPLI-1                  LPLl-1/PM              LPLI-1/LA          LPLI-1/BC NAME DWoodyatt                  DPickett              SLittle            MKowal DATE      09 /13/ 07          09 /13/ 07            09 /12/ 07          09 /18/ 07 OFFICIAL RECORD COPY


==81.0  INTRODUCTION==
Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 cc:
In SECY-00-045, "Acceptance of NEI [Nuclear Energy Institute] 99-04, 'Guidelines forManaging NRC Commitments,'" dated February 22, 2000, the NRC staff informed the Commission that it had found that NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments made by power reactor licensees to the NRC. A "regulatory commitment," as defined in NEI 99-04, is an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.NEI 99-04 provides the NRC staff and its stakeholders with a common reference for handlingregulatory commitments made by the licensees for commercial nuclear reactors to the NRC staff. According to NEI 99-04, a "regulatory commitment" is an explicit statement to take a specific action agreed to, or volunteered by a licensee, and submitted in writing on the docket to the NRC. Internal NRC staff guidance directs the NRR Project Manager to "audit the 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. 2.0AUDIT PROCEDURE AND RESULTSSince no audit was performed before the issuance of NEI 99-04, the NRC staff defined theperiod covered by this audit to go back approximately 3 years. The audit was performed at the Calvert Cliffs Nuclear Power Plant Licensing Office in Lusby, Maryland, on August 14, 2007.2.1Verification of Licensee's Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented thosecommitments made to the NRC as part of past licensing activities. The staff examined a sample of completed commitments to ensure that they were implemented in a manner that  satisfied both the action committed to and the overall intent of the commitment. The licenseeviews a commitment as any action they agree to perform. The staff's findings are summarized in the attached table.2.2Verification of Licensee's Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensee's performance related to implementingcontrols for modifying or deleting commitments made to the NRC. The staff examined the licensee's commitment tracking system and the NRC commitment management procedures.When the licensee incorporates commitments into plant procedures, the licensee includes areference code to the document originating the commitment. If the licensee changes or deletes a commitment, the licensee's procedure directs their staff to use the Commitment Evaluation Form, incorporated from NEI 99-04 guidance.The licensee submits Changes to Commitments Made to the NRC as an attachment to theannual revision of the Updated Final Safety Analysis Report. This attachment describes theoriginal commitment, describes the change, and provides the justification for the change. The licensee has submitted 1 change notification to the NRC in the past 3 years. The commitment changes were submitted to the NRC by letter dated September 8, 2005. The NRC staff also examined a change letter dated December 19, 2002. The staff determined that the commitment changes were made in accordance with the licensee's programs and procedures.
Mr. Michael J. Wallace, President                  Regional Administrator, Region I Constellation Generation Group                      U.S. Nuclear Regulatory Commission 750 East Pratt Street                              475 Allendale Road Baltimore, MD 21202                                King of Prussia, PA 19406 Mr. John M. Heffley                                Ms. Kristen A. Burger, Esquire Senior Vice President and                          Maryland People's Counsel Chief Nuclear Officer                              6 St. Paul Centre Constellation Generation Group                      Suite 2102 1997 Annapolis Exchange Parkway                    Baltimore, MD 21202-1631 Suite 310 Annapolis, MD 21401                                Ms. Patricia T. Birnie, Esquire Co-Director President                                          Maryland Safe Energy Coalition Calvert County Board of                            P.O. Box 33111 Commissioners                                      Baltimore, MD 21218 175 Main Street Prince Frederick, MD 20678                          Mr. Roy Hickok NRC Technical Training Center Mr. Carey Fleming, Esquire                          5700 Brainerd Road Sr. Counsel - Nuclear Generation                    Chattanooga, TN 37411-4017 Constellation Generation Group, LLC 750 East Pratt Street, 17th floor Baltimore, MD 21202 Mr. Jay S. Gaines Director, Licensing Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, MD 20685 Mr. R. I. McLean, Manager Nuclear Programs Power Plant Research Program Maryland Department of Natural Resources 580 Taylor Avenue (B wing, 3rd floor)
The licensee's technical evaluations adequately justified the change, and the NRC was informed of commitment changes that have safety or regulatory significance. The licensee's procedures for changing commitments follow the guidance of NEI 99-04.
Tawes State Office Building Annapolis, MD 21401


==3.0CONCLUSION==
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
Based on the above, the NRC staff concludes that; (1) the licensee had implemented or istracking for future implementation regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDITBetty DoughPatricia Furio Craig NeymanPrincipal Contributor: Diana Woodyatt, NRR Date: September 18, 2007
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
CALVERT CLIFFS NUCLEAR POWER PLANT, INC.
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318
 
==1.0      INTRODUCTION==
 
In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing NRC Commitments, dated February 22, 2000, the NRC staff informed the Commission that it had found that NEI 99-04, Guidelines for Managing NRC Commitment Changes, contains acceptable guidance for controlling regulatory commitments made by power reactor licensees to the NRC. A regulatory commitment, as defined in NEI 99-04, is an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.
NEI 99-04 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by the licensees for commercial nuclear reactors to the NRC staff. According to NEI 99-04, a regulatory commitment is an explicit statement to take a specific action agreed to, or volunteered by a licensee, and submitted in writing on the docket to the NRC. Internal NRC staff guidance directs the NRR Project Manager to audit the licensees commitment management program by assessing the adequacy of the licensees implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.), and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
2.0      AUDIT PROCEDURE AND RESULTS Since no audit was performed before the issuance of NEI 99-04, the NRC staff defined the period covered by this audit to go back approximately 3 years. The audit was performed at the Calvert Cliffs Nuclear Power Plant Licensing Office in Lusby, Maryland, on August 14, 2007.
2.1      Verification of Licensees Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented those commitments made to the NRC as part of past licensing activities. The staff examined a sample of completed commitments to ensure that they were implemented in a manner that Enclosure
 
satisfied both the action committed to and the overall intent of the commitment. The licensee views a commitment as any action they agree to perform. The staffs findings are summarized in the attached table.
2.2    Verification of Licensees Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensees performance related to implementing controls for modifying or deleting commitments made to the NRC. The staff examined the licensees commitment tracking system and the NRC commitment management procedures.
When the licensee incorporates commitments into plant procedures, the licensee includes a reference code to the document originating the commitment. If the licensee changes or deletes a commitment, the licensees procedure directs their staff to use the Commitment Evaluation Form, incorporated from NEI 99-04 guidance.
The licensee submits Changes to Commitments Made to the NRC as an attachment to the annual revision of the Updated Final Safety Analysis Report. This attachment describes the original commitment, describes the change, and provides the justification for the change. The licensee has submitted 1 change notification to the NRC in the past 3 years. The commitment changes were submitted to the NRC by letter dated September 8, 2005. The NRC staff also examined a change letter dated December 19, 2002. The staff determined that the commitment changes were made in accordance with the licensees programs and procedures.
The licensees technical evaluations adequately justified the change, and the NRC was informed of commitment changes that have safety or regulatory significance. The licensees procedures for changing commitments follow the guidance of NEI 99-04.
 
==3.0    CONCLUSION==
 
Based on the above, the NRC staff concludes that; (1) the licensee had implemented or is tracking for future implementation regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.
4.0     LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Betty Dough Patricia Furio Craig Neyman Principal Contributor: Diana Woodyatt, NRR Date: September 18, 2007


==Attachment:==
==Attachment:==
As stated Attachment-1-AUDIT OF CONSTELLATION ENERGY MANAGEMENT OFREGULATORY COMMITMENTSAT CALVERT CLIFFS NUCLEAR POWER PLANTPERFORMED AUGUST 14, 2007LIST OF COMMITMENTS INCLUDED IN AUDITItem No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure1CT20040003109/21/2004In order to verify that interim compensatorymeasures (ICM) for independent spent fuel storage installations (ISFSI) remain unchanged, the licensee must respond to the NRC in writing within 10 days of receipt of 09/10/2004 letter from NRC;  
As stated
 
AUDIT OF CONSTELLATION ENERGY MANAGEMENT OF REGULATORY COMMITMENTS AT CALVERT CLIFFS NUCLEAR POWER PLANT PERFORMED AUGUST 14, 2007 LIST OF COMMITMENTS INCLUDED IN AUDIT Item Commitment  Commitment    Description of Commitment                    Status Method of Closure No. No.         Date 1    CT200400031 09/21/2004    In order to verify that interim compensatory Closed Nuclear Security reviewed the measures (ICM) for independent spent fuel           ISFSI ICMs and determined storage installations (ISFSI) remain               that the activities found in the unchanged, the licensee must respond to             Security Plan and Contingency the NRC in writing within 10 days of receipt       Plan for the ISFSI did not of 09/10/2004 letter from NRC;  


==Subject:==
==Subject:==
decrease the effectiveness of Implementation Status of Independent                the ISFSI ICMs. A letter dated Spent Fuel Storage Installation Interim            09/27/2004 was sent to the Compensatory Measures (TAC Nos.                    NRC stating the effectiveness MC2900 and MC2901)                                  of the ISFSI ICMs.
2    CT200400033 09/28/2004    Amendment Nos. 269 and 245 remove            Closed Two groups within the Calvert Technical Specification (TS) 5.5.3, Post-          Cliffs organization reviewed the Accident Sampling System, from Calvert            safety evaluation and Cliffs Nuclear Power Plant Unit Nos. 1 and          determined that the TS were 2, respectively. Commitment is to review            correct.
safety evaluation report deleting TS 5.5.3 and check the TS for accuracy.
Attachment


Implementation Status of Independent Spent Fuel Storage Installation Interim Compensatory Measures (TAC Nos.
Item Commitment  Commitment Description of Commitment                      Status Method of Closure No. No.         Date 3    CT200400041 12/17/2004 Determine participants for January 14, 2005    Closed The names, titles, NRC workshop on enhancing reactor                     organizations, and details of mitigative measure and strategies. Email, to          participants were sent to the the NRC, the name, title and organization             NRC.
MC2900 and MC2901) ClosedNuclear Security reviewed theISFSI ICMs and determined that the activities found in the Security Plan and Contingency Plan for the ISFSI did not decrease the effectiveness of the ISFSI ICMs. A letter dated 09/27/2004 was sent to the NRC stating the effectiveness of the ISFSI ICMs.2CT20040003309/28/2004Amendment Nos. 269 and 245 removeTechnical Specification (TS) 5.5.3, "Post-Accident Sampling System," from Calvert Cliffs Nuclear Power Plant Unit Nos. 1 and 2, respectively. Commitment is to review safety evaluation report deleting TS 5.5.3 and check the TS for accuracy.ClosedTwo groups within the CalvertCliffs organization reviewed the safety evaluation and determined that the TS were
for participants granted unescorted access and the name, title, organization, date of birth, social security number, and finger print checks for all participants that have not been granted unescorted access. Inform NRC if participants need special accommodations December 27, 2004.
 
Item Commitment  Commitment Description of Commitment                    Status Method of Closure No. No.         Date 4    CT200500008 02/22/2005 Relief request - Weld overlay and alternative Closed Parts 1, 3, 4, and 5 were techniques, Third Ten-Year Inservice                 discontinued from commitment.
correct. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure3CT20040004112/17/2004Determine participants for January 14, 2005NRC workshop on enhancing reactor mitigative measure and strategies. Email, to the NRC, the name, title and organization for participants granted unescorted access and the name, title, organization, date of birth, social security number, and finger print checks for all participants that have not been granted unescorted access. Inform NRC if participants need special accommodations December 27, 2004.ClosedThe names, titles,organizations, and details of participants were sent to the NRC. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure4CT20050000802/22/2005Relief request - Weld overlay and alternativetechniques, Third Ten-Year Inservice Inspection Interval. (1) Demonstrate production weld within heat sink temperature limits by testing on a conservative mockup. (2) Regularly monitor production welds with contact pyrometers and/or temperature indicating crayons, record. (3) Use mockups to identify first weld layer where a 24% minimum Cr content is achieved over the base materials.
Inspection Interval. (1) Demonstrate                 Part 2 was completed by production weld within heat sink                     chemical analysis by x-ray temperature limits by testing on a                   fluorescence performed on conservative mockup. (2) Regularly monitor           overlay layers on mockups; an production welds with contact pyrometers             analysis was performed above and/or temperature indicating crayons,               ferritic, Alloy 82/182, and record. (3) Use mockups to identify first           austenitic stainless steel base weld layer where a 24% minimum Cr                   metals; the second layer content is achieved over the base materials.         contained a Cr content greater (4) Production structural overlay performed         than 24% and therefore with same welding parameters as mockups.             credited toward design (5) Ultrasonic inspection of weld overlay.           thickness. Part 6 was closed (6) Monitor process temperatures, provide           by documenting the manual record, calibrate pyrometers in               temperatures taken during accordance with Measuring and Test                   installation of the weld overlays Equipment (M&TE) program. (7) Apply                 and attaching a copy of the 360° full structural weld overlay to control         M&TE calibration data. Part 7 crack growth, maintain weld integrity.              was closed by documenting the installation of a 360° weld overlay on the hot leg drain nozzle and the cold leg letdown nozzle.
(4) Production structural overlay performed with same welding parameters as mockups.
Item Commitment  Commitment Description of Commitment                  Status Method of Closure No. No.         Date 5    CT200500013 03/13/2005 Request for Approval of a Common Quality    Closed The request for approval of a Assurance (QA) Program for Constellation           common QA Program was Generation Group, LLC. - Review the               withdrawn 08/24/2005 in a Calvert Cliffs QA Policy and the QA Topical       letter from the licensee.
(5) Ultrasonic inspection of weld overlay.
Report to ensure all commitments to Regulatory Guides and standards that are in the Calvert Cliffs QA Policy and not in the QA Topical Report are relocated to the Updated Final Safety Analysis Report.
(6) Monitor process temperatures, provide manual record, calibrate pyrometers in accordance with Measuring and Test Equipment (M&TE) program. (7) Apply 360° full structural weld overlay to control crack growth, maintain weld integrity.ClosedParts 1, 3, 4, and 5 werediscontinued from commitment.
6    CT200500020 05/20/2005 Review Draft Regulatory Guide DG-8029,     Closed Calvert Cliffs Health Physics proposed Revision 2 to Regulatory Guide           department reviewed the draft 8.7, Instructions for Recording and             guide and concluded that the Reporting Occupational Radiation Dose             draft has no new requirements Data and provided comments to the NRC             and was created for the via http://www.nrc.gov/what-we-                   purpose of providing greater do/regulatory/rulemaking.html.                     clarification to the user when recording and reporting radiation dose data and there are no comments for the NRC.
Part 2 was completed by chemical analysis by x-ray fluorescence performed on overlay layers on mockups; an analysis was performed above ferritic, Alloy 82/182, and austenitic stainless steel base metals; the second layer contained a Cr content greater than 24% and therefore credited toward design thickness. Part 6 was closed by documenting the temperatures taken during installation of the weld overlays and attaching  a copy of the M&TE calibration data. Part 7 was closed by documenting the installation of a 360° weld overlay on the hot leg drain nozzle and the cold leg letdown nozzle. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure5CT20050001303/13/2005Request for Approval of a Common QualityAssurance (QA) Program for Constellation Generation Group, LLC. - Review the Calvert Cliffs QA Policy and the QA Topical Report to ensure all commitments to Regulatory Guides and standards that are in the Calvert Cliffs QA Policy and not in the QA Topical Report are relocated to the Updated Final Safety Analysis Report.ClosedThe request for approval of acommon QA Program was withdrawn 08/24/2005 in a letter from the licensee.6CT20050002005/20/2005Review Draft Regulatory Guide DG-8029,proposed Revision 2 to Regulatory Guide 8.7, " Instructions for Recording and Reporting Occupational Radiation Dose Data" and provided comments to the NRC via http://www.nrc.gov/what-we-do/regulatory/rulemaking.html.ClosedCalvert Cliffs Health Physicsdepartment reviewed the draft guide and concluded that the draft has no new requirements and was created for the purpose of providing greater clarification to the user when recording and reporting radiation dose data and there are no comments for the NRC.7CT20050002808/23/2005Provide input and respond to NRC Requestfor Additional Information regarding requirements related to positive reactivity additions from NRC letter dated 08/19/2005.ClosedOn 09/16/2005 Calvert Cliffssubmitted a letter to the NRC with their response to the request for additional information. Item No.Commitment No.CommitmentDateDescription of CommitmentStatusMethod of Closure8CT20050003210/04/2005Underwater welding of heated junctionthermocouple (HJTC) probe holders.
7    CT200500028 08/23/2005 Provide input and respond to NRC Request    Closed On 09/16/2005 Calvert Cliffs for Additional Information regarding               submitted a letter to the NRC requirements related to positive reactivity       with their response to the additions from NRC letter dated 08/19/2005.       request for additional information.
Perform mockup testing for welders using similar materials and under similar conditions as the production welds. Perform inspection of sample welds to the same requirements as the production welds.
Item Commitment  Commitment Description of Commitment                      Status Method of Closure No. No.         Date 8    CT200500032 10/04/2005 Underwater welding of heated junction          Closed Welder qualification completed thermocouple (HJTC) probe holders.                   through mockup testing and Perform mockup testing for welders using             inspections performed as similar materials and under similar                   specified. A work order was conditions as the production welds. Perform           developed to perform HJTC inspection of sample welds to the same               probe holders to the UGS plate requirements as the production welds.                 in compliance with the Verify that the weld procedure specification         requirements of ASME Section approved for use in welding HJTC probe               IX and Code Case N-516-G-3, holders to the upper guide structure (UGS)           Revision 2.
Verify that the weld procedure specification approved for use in welding HJTC probe holders to the upper guide structure (UGS) plate is qualified with tensile and bend tests in accordance with ASME Section IX, and the additional requirements of Code Case N-516-2. Verify complete within schedule.ClosedWelder qualification completedthrough mockup testing and inspections performed as specified. A work order was developed to perform HJTC probe holders to the UGS plate in compliance with the requirements of ASME Section IX and Code Case  N-516-G-3, Revision 2. 9CT20050003811/07/2005Review NRC Regulatory Issue Summary(RIS) 2005-25, "Clarification of NRC Guidelines for Control of Heavy Loads," for applicability and program changes. ClosedThe RIS was reviewed forapplicability to the Calvert Cliffs Reactor Vessel Head Replacement Project and the Calvert Cliffs Load Handling Program. The licensee determined that no changes were required to the Reactor Vessel Head Replacement Project or the Load Handling Program as a result of the RIS.}}
plate is qualified with tensile and bend tests in accordance with ASME Section IX, and the additional requirements of Code Case N-516-2. Verify complete within schedule.
9    CT200500038 11/07/2005 Review NRC Regulatory Issue Summary           Closed The RIS was reviewed for (RIS) 2005-25, Clarification of NRC                 applicability to the Calvert Cliffs Guidelines for Control of Heavy Loads, for           Reactor Vessel Head applicability and program changes.                   Replacement Project and the Calvert Cliffs Load Handling Program. The licensee determined that no changes were required to the Reactor Vessel Head Replacement Project or the Load Handling Program as a result of the RIS.
                                                    }}

Latest revision as of 10:56, 13 March 2020

Audit of the Licensee'S Management of Regulatory Commitments (TAC Nos. MD6133 and MD6134)
ML072480261
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 09/18/2007
From: Pickett D
NRC/NRR/ADRO/DORL/LPLI-1
To: Spina J
Calvert Cliffs
Pickett D, NRR/DORL, 415-1364
References
TAC MD6133, TAC MD6134
Download: ML072480261 (10)
v • d • e


Text

September 18, 2007 Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)

Dear Mr. Spina:

An audit of the commitment management program was performed at the Calvert Cliffs Nuclear Power Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes.

Details of the audit are described in the enclosed audit report. The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

As stated cc w/encl: See next page

September 18, 2007 Mr. James A. Spina, Vice President Calvert Cliffs Nuclear Power Plant, Inc.

Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6133 AND MD6134)

Dear Mr. Spina:

An audit of the commitment management program was performed at the Calvert Cliffs Nuclear Power Plant (CCNPP) site on August 14, 2007. Based on the audit, the Nuclear Regulatory Commission (NRC) staff concludes; (1) CCNPP has established an effective commitment management program, (2) CCNPP has implemented NRC commitments on a timely basis, and (3) CCNPP has implemented an effective program for managing NRC commitment changes.

Details of the audit are described in the enclosed audit report. The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-1364.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318

Enclosure:

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

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

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

Tawes State Office Building Annapolis, MD 21401

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

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

CALVERT CLIFFS NUCLEAR POWER PLANT, INC.

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

1.0 INTRODUCTION

In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing NRC Commitments, dated February 22, 2000, the NRC staff informed the Commission that it had found that NEI 99-04, Guidelines for Managing NRC Commitment Changes, contains acceptable guidance for controlling regulatory commitments made by power reactor licensees to the NRC. A regulatory commitment, as defined in NEI 99-04, is an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

NEI 99-04 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by the licensees for commercial nuclear reactors to the NRC staff. According to NEI 99-04, a regulatory commitment is an explicit statement to take a specific action agreed to, or volunteered by a licensee, and submitted in writing on the docket to the NRC. Internal NRC staff guidance directs the NRR Project Manager to audit the licensees commitment management program by assessing the adequacy of the licensees implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.), and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS Since no audit was performed before the issuance of NEI 99-04, the NRC staff defined the period covered by this audit to go back approximately 3 years. The audit was performed at the Calvert Cliffs Nuclear Power Plant Licensing Office in Lusby, Maryland, on August 14, 2007.

2.1 Verification of Licensees Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented those commitments made to the NRC as part of past licensing activities. The staff examined a sample of completed commitments to ensure that they were implemented in a manner that Enclosure

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

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

When the licensee incorporates commitments into plant procedures, the licensee includes a reference code to the document originating the commitment. If the licensee changes or deletes a commitment, the licensees procedure directs their staff to use the Commitment Evaluation Form, incorporated from NEI 99-04 guidance.

The licensee submits Changes to Commitments Made to the NRC as an attachment to the annual revision of the Updated Final Safety Analysis Report. This attachment describes the original commitment, describes the change, and provides the justification for the change. The licensee has submitted 1 change notification to the NRC in the past 3 years. The commitment changes were submitted to the NRC by letter dated September 8, 2005. The NRC staff also examined a change letter dated December 19, 2002. The staff determined that the commitment changes were made in accordance with the licensees programs and procedures.

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

3.0 CONCLUSION

Based on the above, the NRC staff concludes that; (1) the licensee had implemented or is tracking for future implementation regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Betty Dough Patricia Furio Craig Neyman Principal Contributor: Diana Woodyatt, NRR Date: September 18, 2007

Attachment:

As stated

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

Subject:

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

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

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

Attachment

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

for participants granted unescorted access and the name, title, organization, date of birth, social security number, and finger print checks for all participants that have not been granted unescorted access. Inform NRC if participants need special accommodations December 27, 2004.

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

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

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

Report to ensure all commitments to Regulatory Guides and standards that are in the Calvert Cliffs QA Policy and not in the QA Topical Report are relocated to the Updated Final Safety Analysis Report.

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

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

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

plate is qualified with tensile and bend tests in accordance with ASME Section IX, and the additional requirements of Code Case N-516-2. Verify complete within schedule.

9 CT200500038 11/07/2005 Review NRC Regulatory Issue Summary Closed The RIS was reviewed for (RIS) 2005-25, Clarification of NRC applicability to the Calvert Cliffs Guidelines for Control of Heavy Loads, for Reactor Vessel Head applicability and program changes. Replacement Project and the Calvert Cliffs Load Handling Program. The licensee determined that no changes were required to the Reactor Vessel Head Replacement Project or the Load Handling Program as a result of the RIS.

Retrieved from "https://kanterella.com/w/index.php?title=ML072480261&oldid=2574635"