ML113201738

Regulatory Commitment Management Program Audit Report

ML113201738
Person / Time
Site:	Point Beach
Issue date:	12/07/2011
From:	Beltz T Plant Licensing Branch III
To:	Meyer L Point Beach
beltz T, NRR/DORL/LPL3-1, 301-415-3049
References
TAC ME6659, TAC ME6660
Download: ML113201738 (23)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 7, 2011 Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, WI 54241 SUB~IECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 - REGULATORY COMMITMENT MANAGEMENT PROGRAM AUDIT REPORT (TAC NOS. ME6659 AND ME6660)

Dear Mr. Meyer:

The enclosed report provides the results of an onsite audit conducted by the U.S. Nuclear Regulatory Commission (NRC) staff during the period of October 17 - 19, 2011, of the regulatory commitment management program at the Point Beach Nuclear Plant, Units 1 and 2.

The purpose of the audit was to examine the NextEra Energy Point Beach (the licensee) regulatory commitment management program and the regulatory commitment change progress.

The NRC staff examined the licensee's commitment management records, including a sample of regulatory commitments that have not been previously inspected or otherwise audited by the NRC staff, that are risk significant, and that were important to the NRC staffs decision-making process on the licensing actions for which the respective commitments were made.

Based on the results of the audit, the NRC staff concludes that the licensee has effectively implemented the regulatory commitment management program. The regulatory commitment management program and the regulatory commitment change process were effectively implemented consistent with the Nuclear Energy Institute's (NEI) industry guidance NEI 99-04, and were generally in accordance with the NRC staff's Office Instruction LlC-105. Details of the audit and the NRC staffs conclusions are set forth in the enclosed audit report.

l. Meyer

- 2 The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, I can be contacted at (301) 415-3049.

Sincerely, Te A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

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 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301

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 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes" (ADAMS Accession No. ML003680088) contains acceptable guidance for controlling regulatory commitments, and encourages licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented, that changes to the regulatory commitments are evaluated, and when appropriate, reported to the NRC. In accordance with NEI 99-04, the NRC is informed of any regulatory commitment change that has safety or regulatory significance. The value of maintaining a working commitment management program is that it supports a common understanding by licensees, the NRC staff, and other stakeholders of how a licensing issue is resolved and how the matter will be controlled in the future.

The Office of Nuclear Reactor Regulation (NRR) issued Office Instruction LlC-105, "Managing Regulatory Commitments Made by Licensees to the NRC." Revision 3 to LlC-105 was issued on March 30,2009 (ADAMS Accession No. ML090640415). LlC-105 provides the NRC staff and its stakeholders a reference for handling regulatory commitments made by the licensees for commercial nuclear power reactors. The guidance provided in LlC-105 is consistent with industry guidance prepared by NEI in NEI 99-04.

As defined in NEI 99-04 and LlC-105, 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. The guidance provided in LlC-105 instructs the NRR Project Managers 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.). LlC-105 provides a recommendation that a regulatory commitment management audit be performed every three years.

Enclosure

- 2 On October 17 - 19, 2011, the NRC staff periormed an audit of the regulatory commitments management program at the Point Beach Nuclear Plant (Point Beach). NextEra Energy Point Beach, LLC (the licensee) is the holder of the renewed facility operating license for Point Beach, Units 1 and 2.

A summary of the NRC staff's activities, reviews, and conclusions is outline below.

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Point Beach commitment management program was conducted at the site from October 17 through 19, 2011. The scope of the audit focused primarily on reviewing regulatory commitments that the licensee opened, closed, or extended in the past three years. The previous commitment management audit at Point Beach was periormed during the period of April 28 through May 1, 2008, and was documented in an audit report dated June 18, 2008 (ADAMS Accession No. ML081270075).

The information that the NRC staff reviewed consisted of commitments identified through a search through ADAMS for licensee-submitted documents and NRC-approved licensing actions, in addition to a list of commitments and associated documentation provided by the licensee through its Regulatory Information System (RIS) database. Regulatory commitments are maintained in the RIS database. The licensee uses the RIS database as a regulatory commitment "historical repository," and it is not a mechanism for directly tracking regulatory commitments. The RIS database also allows individuals to periorm commitment searches via key words or dates.

For this audit, the NRC staff reviewed a sample of the licensee's regulatory commitments, including any associated tracking and close-out documentation provided from the RIS database.

The NRC staff reviewed the licensee's commitment management program implementing procedures. The NRC staff also requested associated documents that were directly or indirectly affected by the commitments to verify that the licensee implemented all relevant changes that were impacted by the commitment.

The audit consisted of two major parts: (1) verification of the licensee's program for managing regulatory commitment changes, and (2) verification of the licensee's management and implementation of regulatory commitments.

2.1 Verification of the Licensee's Program for Managing Regulatory Commitment Changes The NRC staff reviewed two licensee procedures related to the Regulatory Commitment Management Program:

(1) NextEra Energy licenSing Desk-Top Instruction, LI-AA-204-1000-10000, "Commitment Tracking," Revision 3, dated May 25, 2011.

(2) Point Beach Nuclear Plant Procedures Manual, NP 5.1.7, "Regulatory Commitment Management," Revision 17, dated June 15, 2011.

- 3 administrative controls necessary for effectively managing regulatory commitments, including tracking, changing, modifying or deleting commitments made to the NRC. The NRC staff compared NextEra Energy nuclear fleet procedure U-AA-204-1 000-1 0000 to NEI 99-04, to determine whether the procedure is consistent with the guidance in NEI 99-04 for evaluating and reporting changes to regulatory commitments. The NRC staff reviewed the Point Beach Nuclear Plant site administrative procedure NP 5.1.7 for consistency with the processes delineated in U-AA-204-1 000-10000 and the guidance provided in NEI-99-04. The NRC staff also reviewed documentation associated with a sample of commitment changes.

2.1.1 Audit Results In Section 3.4 of Fleet Procedure U-AA-204-1 000-1 0000, the licensee defines a "Regulatory Commitment" as the following:

An explicit statement to take a specific action agreed to or volunteered by FPUNextEra and submitted in formal NRC Correspondence to the NRC by authorized management. Regulatory Commitments are considered part of the licensing basis of a nuclear power plant. Regulatory Commitments may be one time or ongoing commitments.

A Regulatory Commitment is appropriate for matters in which the NRC has a significant interest but which do not warrant either a legally binding requirement or inclusion in the licensing basis or a program subject to a formal regulatory change control mechanism.

U-AA-204-1000-10000 provides guidance for determining who defines regulatory commitments, who is authorized to make regulatory commitments, and who can sign correspondence to the NRC.

NP 5.1.7 further defines the responsibilities and process for management of regulatory commitments at PBNP, and is used in conjunction with U-AA-204-1000-10000. In NP 5.1.7, the licensee states the following:

• Obligations cannot be changed using the commitment change process.

• Obligations are legally binding requirements and can only be modified via established regulatory processes and approved by the NRC.

• Regulatory Commitment changes requiring notification of the NRC shall be summarized in the annual 10 CFR 50.59 report or the NRC shall be notified on a schedule as determined by the proposed change. The summary of the changes provided in the 10 CFR 50.59 report shall include a description of the change in commitment and the basis for the change.

These statements regarding changes to obligations and regulatory commitments are consistent with the guidance provided in NEI 99-04.

-4 The NRC staff found that U-AA-204-1000-10000 closely adheres to the commitment management guidelines of NEI 99-04, and that NP 5.1.7 provides a consistent methodology for defining the process and responsibilities associated with the onsite management of regulatory commitments. The NRC staff concludes that the procedures used by the licensee to manage commitment changes appear adequate.

The NRC staff identified that procedure NP 5.1.7 provided adequate guidance for documenting regulatory commitment changes. The commitment management change process flow diagram in NP 5.1.7, Attachment A, mirrors that of NEI 99-04, Figures A-1 and A-2. The commitment change methodology provided in NEI 99-04, Figure A-3, is similarly reflected in the licensee's Form PBF-1640, "Commitment Change Evaluation."

The NRC staff reviewed a sample of regulatory commitments that had been changed which required NRC notification. The NRC staff also reviewed regulatory commitments that had been changed and did not require NRC notification. The NRC staff observed that the licensee had generally complete and accurate records for review. Those commitment management changes that were reviewed by the NRC staff were appropriately documented.

2.2 Verification of Licensee's Management and Implementation of Regulatory Commitments The primary focus of the NRC staff audit was to confirm that the licensee has managed and implemented commitments made to the NRC as part of past licensing actions/activities in accordance with NRC guidance and approved plant procedures, and to verify that changes to regulatory commitments were effectively managed. For commitments not yet implemented, the NRC staff reviewed the program to verify that adequate controls are established to effectively ensure future implementation.

2.2.1 Audit Scope Prior to the audit, in order to generate a list of items for the audit, the NRC staff performed ADAMS searches for commitments and reviewed summary reports from the licensee's commitment tracking database. From the results of these searches, the NRC staff selected a representative sample of regulatory commitments to audit. The sample covered a variety of systems, disciplines, commitment changes, and licensing actions.

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

(1)

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

(2) Commitments that pertain to milestones of licenSing actions/activities (e.g., 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.

- 5 (3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical SpeCifications, and the Final Safety Analysis Report. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

The NRC staff also reviewed four obligations (i.e., license conditions) to verify adequate implementation and closure by the licensee. One of the obligations was developed from a licensee commitment that the NRC staff subsequently determined should be a license condition in support of a reasonable assurance determination during review of a license amendment request.

The specific closed, open, and changed commitments selected for the audit are listed in Table 1 at the end of this report.

2.2.2 Audit Results The NRC staff reviewed NextEra Energy fleet procedure U-AA-204-1 000-1 0000 and Point Beach administrative procedure NP 5.1.7 to determine whether the licensee had an effective program in place to identify, manage, and close commitments made to the NRC as part of licensing actions/activities. In addition, the NRC staff reviewed the selected sample of open and closed commitments to confirm that the licensee had implemented closed commitments appropriately, and that commitments still open had been captured in an effective program for future implementation. In addition to the above-cited procedures, the NRC staff reviewed relevant reports and summary sheets providing the status of each commitment, tracking and change forms, and associated documentation, as appropriate (e.g., plant procedures, examination records, and/or other plant documentation).

The NRC staff compared the guidance in procedures U-AA-204-1 000-1 0000 and NP 5.1.7 to the guidance in NEI 99-04. The NRC staff also found that roles and responsibilities, processes, and metrics were clearly identified in the procedures. The NRC staff concluded that the procedures were consistent with the NEI guidance for identifying, managing, and closing regulatory commitments.

The NRC staff reviewed the documentation associated with the sampled closed regulatory commitments, particularly plant procedures that had been revised as a result of the commitments, and found that the commitments reviewed had been closed in a manner that satisfied the commitments made to the NRC. The NRC staff noted that the method of linking specific changes in procedures to specific regulatory commitments was adequate and resulted in traceability in the most recently-revised procedures.

The NRC staff found that the licensee's commitment tracking program had captured the sampled open regulatory commitments in sufficient detail to clearly identify the due date, the responsible staff, and the necessary steps and actions required to fully close out the commitment.

- 6 2.3 Audit Observations The NRC staff made the following observations during the audit, which are considered minor in nature:

• The NRC staff found that the licensee's commitment tracking program had adequately captured all of the audited regulatory commitments.

• Although the commitment management tracking software does not automatically generate reminders to the responsible departments for upcoming commitment due dates, management oversight of the process appears to currently provide adequate control to ensure due dates are being adequately tracked.

Providing a detailed list of commitment documents in the RIS commitment database is a positive aspect of the commitment management system and aids tracking and final closure of commitments. However, some documents provided in the database were either not applicable to the specific commitment or documentation was lacking that could assist in verification that the commitment was either changed or closed.

• As in the previously completed audit completed in 2008, it was disclJssed with the licensee that there is currently no simple mechanism to determine if there are related commitments (Le. numerous commitments in one letter). Each commitment is still tracked individually, although there is an effort to link related regulatory commitments manually in the system.

• There was not always a clear nexus provided for commitments closed through licensing actions. The commitment management process provides guidance for changing commitments without prior NRC notification and those changes appear to be adequately documented and reported via the periodic 10 CFR 50.59 summary report. It was recommended that commitment changes resulting from NRC staff approval of licensing actions be clearly addressed in the licensee's submittals to provide a clearer and more transparent link between approval of the licensing action and any change of commitments.

As an example, the licensee determined that commitments associated with the reactor vessel head drop (RVHD) analysis could be deleted based upon NRC staff approval of license amendment request associated with a new RVHD analysis.

The previous commitments were administratively controlled through the Technical Requirements Manual (TRM). The license's amendment request associated with changing the RVHD analysis did not specifically identify that these regulatory commitments were to be deleted upon NRC approval and, therefore, the NRC staff's safety evaluation report (SER) did not identify that previous regulatory commitments would be closed upon approval of this licensing action.

In contrast, the licensee specifically stated in its license amendment request dated July 24, 2008 (ADAMS Accession No. Ml082240685) that commitments

- 7 associated with testing of Boraflex panels under the Boraflex surveillance program will no longer be effective upon NRC approval and implementation. The NRC staff subsequently concurred with the licensee's proposal in a SER for the approved amendment (ADAMS Accession No. ML100400106).

The commitment management process provides guidance allows for changing commitments without requiring prior NRC notification. In NP 5.1.7, Section 4.2.10, a Note states that Licensing may elect to notify the NRC prior to changing a Regulatory Commitment even though the change process would not require such action, dependent upon the nature of the issue and proposed change. It is recommended that commitment changes resulting from approval of licensing actions be specifically addressed in the licensee's request and subsequently reflected in the NRC staffs SER to provide a clear and transparent link between approval of the licensing action and subsequent change to the regulatory commitment.

The above observations were discussed with your staff during the audit.

3.0 CONCLUSION

The NRC staff concludes, based on this audit, that: (1) the licensee has an effective program for implementing and managing regulatory commitments, and (2) the licensee has an effective program for managing changes to regulatory commitments.

Based on the results of the audit, the NRC staff concludes that the licensee appears to have an effective program for managing regulatory commitments in accordance with the guidance provided in NEI 99-04.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT James Costedio Licensing Manager Fritzie Flentje Licensing Supervisor Tom Kendall Engineering Brenda Scherrwinski Licensing Kim Locke Licensing Principal Contributor: Terry Beltz

Attachment:

Summary of Audit Results

ATTACHMENT

SUMMARY

OF AUDIT RESULTS REGULATORY COMMITMENT AUDIT PERFORMED FROM OCTOBER 17 -19, 2011 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

TABLE 1 Audit Summary: Written Commitments and Related Information NextEra Energy Point Beach, LLC Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301 RIS 10 Oescript;on Of Commitment OocumentsReviewed Status Auditor's Assessment 98 NUREG-0737, Item 111.0.3.4, Control Room Habitability Requirements There are two kits of self-contained breathing apparatus (SCBA) and two Biopak-60 units in the control room. Elsewhere on site, there are 18 other Biopak-60 units and 5 more SCBAs.

Alternate Source Term (AST) Amendment Nos. 240/244 dated 04114/2011 (ML110240054)

TS 5.5.18, "Control Room Envelope Habitability Program" NP 7.7.29, Rev. 2, "Control Room Envelope Habitability Program" EPMP 1.1 b, Rev. 33, "Radiation Protection Emergency Preparedness Quantity Check" Complete 04/14/2011 Active Ongoing The commitment is being met.

No issues identified - adequate.

Related documents did not provide information related to the required inventory of Biopak-60 units to be available for the control room. Supporting information was subsequently provided by the licensee.

.......~

- 2 RIS 10 Description Of Commitment Documents Reviewed Status Auditor's Assessment 102 NUREG-0737, Item 111.0.3.4, Control Room Habitability Requirements A bottle of potassium iodine (KI) tablets will be stored in the control room. As revised by Amendments 240/244, administration of KI to control room operators was eliminated for AST radiological analyses unless control room emergency filtration system (CREFS) is out of service and CREFS mitigating system is in service. Per NP 7.7.29, 80 containers are required.

Wisconsin Electric letter dated 02/23/1981 "Additional Responses to NUREG-0737, Post-TMI Requirements for Operating Plants" AST Amendment Nos. 240/244 dated 04114/2011 (ML110240054)

NP 7.7.29, Rev. 2, "Control Room Envelope Habitability Program" EPMP 1.1 b, Rev. 33, "Radiation Protection Emergency Preparedness Quantity Check" EPIP 5.2, Rev. 16, "Radioiodine Blocking and Thyroid Dose Accounting" Final Safety Analysis Report (FSAR) 9.8, Rev. 2, 08/12/2011 (markup), "Control Room Ventilation System (VNCR)"

Complete 04/14/2011 Active Ongoing Verified that the commitment is being met.

No issues identified - adequate.

366 8084 A once per shift check of auxiliary feedwater (AFW) piping temperatures is required at PBNP and is included in the PBNP Unit 1 turbine building auxiliary operator logs. This check will continue to be made. AOP-2C, Auxiliary Feedwater Pump Steam Binding or Overheating, addresses recognition of potential and actual steam binding and restoration actions at PBNP.

Wisconsin Electric Power Company letter dated 04/12/1988 PBF-2031, Rev. 95, "Aux Bldg Log" PBF-2032, Rev. 95, "Turbine Bldg Log" AOP-2C Unit 1, Rev. 8, "Auxiliary Feed Pump Steam Binding or Overheating" FSAR Section 10.2, "Auxiliary Feedwater System (AF)" and FSAR Section 10.2.4, "Required Procedures and Tests" Complete 05/23/2011 Inactive Ongoing Verified that the commitment is being met.

Reviewed licensee procedures and FSAR Section 10.2.

No issues identified - adequate.

......-.......~.--

- 3 RIS 10 pe!j~ription Oteorpm{tment OocumentsReviewed Status Audllor"sAssessment

~.. <';;,.. "

9870 In-situ blackness testing of at least then full-length Boraflex panels every year will be continued under the current Boraftex surveillance program.

CCE 2007-001, Rev. 1, dated 04/13/1989 Wisconsin Electric Power Company letter dated 11/30/1998 Letter from FPL to NRC dated 07/24/2008 requesting approval of license amendment re:

spent fuel pool storage criticality control (ML082240685)

Letter from NRC dated 03/05/2010 issuing Amendment Nos. 236 and 240 (ML100400106)

Complete 03/05/210 Verified that commitment was met and closed properly.

No issues identified - adequate.

6483

-4 StatQ$

Verified that the commitment is 10054 INUREG-0737, Item III.D.3.4, Control lAST Amendment Nos. 240/244 dated 04114/2011 IComPlete Room Habitability Requirements (ML110240054) 05/04/2011 being met.

Emergency equipment has been Correction letter associated with AST Amendment IActive No issues identified - adequate.

provided in the control room Nos. 240/244 dated 05104/2011 assuming a complement of 6 (ML111220078)

I Ongoing The supporting documents did not people.

include information specifying the Letter from NRC dated 08/10/1982 with attached required inventory of SCBA and letter from Battelle PNL dated 02/02/1982 Biopak-60 units to be available for Additional SCBAs were needed to the control room. Supporting provide adequate protection for the TS 5.5.18, "Control Room Envelope Habitability information was subsequently normal complement of personnel in Program" provided by the licensee.

the control room and to meet single failure criteria. The licensee NP 7.7.29, Rev. 2, "Control Room Envelope committed to a number of Habitability Program" modifications, including control room, door and window portable EPMP 1.1 b, Rev. 33, "Radiation Protection shielding and control room air Emergency Preparedness Quantity Check" supply line radioactive gas detection equipment. In addition to those FSAR 9.8, Rev. 2, 08/12/2011 (markup), "Control measures proposed by the licensee Room Ventilation System (VNCR)"

in its submittals, Pacific Northwest Laboratories (PNL) indicated that in order to meet Regulatory Guide 1.78, the licensee should provide additional SCBA units for control room personnel.

-10 Q.escription RIS 10 Auditor~sAssessment Documents Reviewed Status Of.Cornmitrnent 14507 NextEra Energy Point Beach, LLC This item is a License Condition.

NRC 2008-0081 dated 12/08/2008 Complete will modify the PBNP control room (ML083450683) 05/20/2011 (CR) radiation shielding to ensure Verified that the obligation was CR habitability requirements are EC 11691 - Addition of Control Room Shielding met and closed properly.

Active maintained. This modification is scheduled to be completed following WO 00365253 05 - AST Mod - Install Control Reviewed engineering change NRC approval of LAR 241, Room Shielding 1Install East Window Shield Wall package and associated work Alternative Source Term, no later orders.

than the Unit 2 (2011) refueling WO 00365253 06 - AST Mod - Install Control outage.

Room Shielding 1Install Shield Wall and Rig Roof No issues identified - adequate.

14510 NextEra Energy Point Beach, LLC WO 00379531 - HV EC 14606 - Modify PAB Complete This item is a License Condition.

will modify the primary auxiliary Exhaust and CREFS HVAC [heating, ventilation, 06/03/2011 building (PAB) ventilation system and air conditioning] for AST Verified that the obligation was (VNPAB) to ensure redundancy of Active met and closed properly.

active components needed to EC 14606 - Modify PAB Exhaust and CREFS operate the PAB exhaust system.

HVAC as Required for Seismic Qualification Reviewed engineering change VNPAB components credited for package and associated work AST will be upgraded to augmented EOP-0.1 Unit 1, Rev. 36, "Reactor Trip Response" order.

quality status. NextEra Energy Point Beach, LLC will revise PBNP EOP-0.1 Unit 2, Rev. 36, "Reactor Trip Response" No issues identified - adequate.

Emergency Operating Procedures (EOPs) to address starting the EOP-O Unit 1, Rev. 54, "Reactor Trip or Safety VNPAB fans. This modification is Injection" scheduled to be completed following NRC's approval of LAR 241, EOP-O Unit 2, Rev. 54, "Reactor Trip or Safety Alternative Source Term, no later Injection" than the Unit 2 (2011) refueling outage.

EOP/AOP Validation Form for EOP-O Unit 1 and EOP-O Unit 2 to restore VNPAB within two hours.

~-

.~

~

--~.... -

- 12 Deseription RISID Of Commitment NextEra shall add clarification to the EOP Background Document and operator training for LOCA response, in that the transfer from containment spray (CS) on emergency core cooling system recirculation to cold leg injection via the safety injection (51) pumps shall occur within 10 minutes. NextEra shall establish this time for the transfer from CS recirculation to 51 cold leg recirculation as a time critical operator action in accordance with the Operations administrative procedure for control of time critical actions.

14541 14532 NextEra Point Beach, LLC shall install a self-cooled (i.e., air-cooled) air compressor capable of supplying Instrument Air. The compressor shall be independent of Service Water cooling and normally aligned for automatic operation. Prior to operation of either unit at EPU conditions.

Doeurnents Reviewed EOP-1.3 Unit 1, Rev. 46, "Transfer to Containment Sump Recirculation - Low Head Injection" EOP-1.3 Unit 2, Rev. 45, "Transfer to Containment Sump Recirculation - Low Head Injection" BG EOP-1.3, Rev. 32, "Transfer to Containment Sump Recirculation - Low Head Injection" NRC 2010-0144 dated 09/09/2010 (ML102520327)

EC263280 - installation of temporary air compressor Status Complete 06/06/2011 Active Ongoing Complete 06/11/2011 Auditor's Assessment Verified that the commitment was met and closed properly.

No issues identified - adequate.

License Condition The commitment is closed.

No issues - adequate.

~

i

ML113201738 Sincerely, IRA!

Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation RidsNrrPMPointBeach Resource RidsNrrDorlLpl3-1 Resource RidsOgcRp Resource MKunowski, Rill RidsRgn3MailCenter Resource SBurton, Rill RidsNrrDorlOpr Resource MThorpe-Kavanaugh, Rill NRR-106 OFFICE LPL3-1/PM LPL3-1/LA LPL3-1/BC (A)

LPL3-1/PM NAME TBeitz BTuily SWiliiams TBeitz DATE 11/29/11 11/ 28/11 12/06/11 12/07/11