ML14006A306

Audit of the Licensees Management of Regulatory Commitments

ML14006A306
Person / Time
Site:	Palisades
Issue date:	01/17/2014
From:	Mahesh Chawla Plant Licensing Branch III
To:	Entergy Nuclear Operations
Chawla M
References
TAC MF1916
Download: ML14006A306 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Vice President, Operations Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530 January 17, 2014

SUBJECT:

PALISADES NUCLEAR PLANT-AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF1916)

Dear Sir:

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 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's Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees' commitment management programs once every three years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and regulatory commitments are being effectively implemented.

An audit of Palisades' commitment management program was performed at the plant site during the period of November 12 through 14, 2013. The NRC staff concludes, based on the audit, that 1) Palisades has implemented NRC commitrryents on a timely basis, and 2) Palisades has implemented "an effective program for managing NRC commitment changes, and (3) with some minor inconsistencies, which were discussed with the licensee during the exit meeting on November 14, 2013, Palisades Nuclear Plant has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report. This audit report covers the commitment management program current at the time of the audit.

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) 415-8371.

Docket No. 50-255

Enclosure:

Audit Report cc w/encl: Distribution via ListServ Sincerely, Mahesh Chawla, Project Manager Plant Licensing Branch 111-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation

LICENSEE MANAGEMENTOF REGULATORY COMMITMENTS PALISADES NUCLEAR PLANT DOCKET NO. 50-255

1.0 INTRODUCTION AND BACKGROUND

The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue Summary (RIS) 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000, that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments. RIS 2000-17 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. NEI 99-04 describes a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee by a certain date and submitted in writing on the docket to the NRC.

The NRC's Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every three years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and regulatory commitments are being effectively implemented. An audit of the Palisades' commitment management program was performed at the plant site during the period November 12 through 14, 2013. The audit reviewed commitments made since the previous audit, reported on November 3, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102710381).

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.).

2.0 AUDIT PROCEDURE AND RESULTS The audit consisted of three major parts: (1) verification of the licensee's implementation of NRC commitments that have been completed, (2) verification of the licensee's program for managing changes to NRC commitments, and (3) verification that all regulatory commitments reviewed were correctly applied in NRC staff licensing action reviews.

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 Enclosure yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation. 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.

2.1.1 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 Lic;ensee 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 search ADAMS for any submittals from the licensee since the last audit [or during in the last 3 years] 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.

(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 and Technical Specifications (TSs).

Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

The licensee provided the list and the documentation to support the NRC staff's audit in each of the sample areas discussed above. The licensee's documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (i.e., plant procedures, examination records, and/or other plant documentation). The attached table lists the commitments selected for this audit.

2.1.2 Audit Results The attached Audit Summary provides details of the audit and results. The NRC staff found that the licensee had successfully implemented the regulatory commitment management process at Palisades Nuclear Plant (PNP). The various aspects of regulatory commitment management are discussed below.

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

The licensee's Commitment Management Program is described in Entergy's Nuclear Management Manual, "EN-LI-11 0", Rev. 5. The purpose of this procedure is to ensure that the commitments made to the NRC in written correspondence are actively managed through the use of a Commitment Management System (CMS). Management includes capturing new commitments, changing existing commitments, and closing/deleting commitments. The procedure does not provide any detailed instructions on how to manage commitments related activities such as entering, changing or closing out the commitments in the database.

Interviews with the Palisades' personnel provided the information on the existing tracking mechanism for commitments. At present, the licensee enters commitments made to the NRC into a comprehensive database called "Paperless Condition Reporting System (PCRS)." The NRC commitments are entered as License Action Requests (LARs). The datab.ase also includes other types of documents such as condition reports (CRs), Work Tasks (WTs) etc. The commitments are searchable by the date of the letter which made the original commitment. If a letter contains more than one commitment, each of the commitments are assigned the same LAR number with a sub-task designator such as LO-LAR-2009-0244-01, where -01 denotes the action number. After the commitments are entered in the system, they get assigned to the appropriate plant personnel in coordination with the respo*nsible department. The PCRS provides the current status of the commitments in addition to other information such as reportability requirements, due date, closure date etc. In the case of NRC commitments, there are also check boxes to ensure concurrence required for closure, and also approval requirement for an extension of a NRC commitment.

The PCRS also sends to the designated personnel, an initial e-mail notification of corrective action assignments and reminders seven days prior to pending corrective action due dates.

Individuals assigned to completing a NRC commitment are responsible for updating PCRS upon completion of the commitment, and also providing the necessary closure documents to the

~Licensing department. The Licensing department Technical Specialist reviews and closes the commitment in PCRS. All pertinent documents related to the commitment are scanned into the system during the closeout process of the commitment. The system maintains all the necessary documentation relating to NRC commitments.

The NRC staff found that the licensee's procedure EN-LI-11 0, Rev.5, meets the intent and is consistent with the guidance provided in NEI 99-04, Rev. 0. If an NRC commitment affects a plant procedure, a cross-reference is provided in the procedure to identify the commitment.

However, there is no distinction made between an "obligation" and a "commitment".

The NRC staff reviewed documentation generated by the licensee related to the sample items listed in the attached table that are categorized as commitments in response to different categories of documents such as PNP Amendments, QA Topical Report, Bulletins and Generic Letters to assess the implementation of the licensee's procedures, including the status of their completion. The licensee had mad~ changes to the commitments using the Commitment Change Evaluation Form (CCEF). The commitment change process is being used to close the commitme.nts in response to the old Licensee Event Reports (LERs), notices of violation (NOVs) and inspection reports (IRs), since these are no longer considered to be commitments. For the sample of commitments selected for the audit, the NRC staff found that the licensee's commitment tracking program had captured all of the regulatory commitments..The review of their PCRS system reflected their status consistent with the program. However, the NRC staff noted that implementation of the program had some minor inconsistencies. These observations are described Section 2.4.

2.2.1 Verification of the Licensee's Program for Managing NRC Commitment Changes The NRC staff reviewed the licensee's procedure EN-LI-110, Rev. 5, against NEI 99-04, Revision 0. Regulatory Commitment Changes are processed and tracked by Site Licensing and are approved by the Site Management. The evaluation of any commitment changes is to be done by filing a CCEF. The NRC staff reviewed this form and found it to be same as the Commitment Change Process described in NEI 99-04.

The NRC staff found that the licensee's procedures for handling the commitment.change are in general, consistent with the guidance in NEI 99-04.

2.2.2 Commitment Changes Reported to the NRC The NRC staffreviewed documentation generated by the licensee related to the sample items listed in the attached table that are categorized as Commitment Change. The NRC staff found that, with a few minor inconsistencies, the licensee had properly addressed each regulatory commitment change selected for this audit and that the licensee had implemented an effective program to manage commitment changes. The NRC staff observations and suggestions are described in Section 2.4.

2.2.3 Commitment Changes Not Reported to the NRC The licensee indicated that there were several commitment changes which were not reported to the NRC. These were related to the old commitments made in response to inspection activities, LERs, etc., which did not meet the definition of commitments in accordance with NEI 99-04.

Therefore, these changes were not reported to the NRC.

2.2.4 Traceability of Commitments Although not specifically stated in the guidance from NEI 99-04, according to LIC-1 05, traceability of the commitments is advantageous for the licensee's control of NRC commitments.

The licensee has improved' their system for tracing commitments that affect procedures. The licensee's procedure for Commitment Management Program, EN-LI-110, Rev.5, section 5.9 addresses changes to documents that implement commitments. This section provides steps for keeping track of the commitments when relocating them to different documents, review of document changes against commitment reports, and. also addresses changes to implementing commitment information.

For example, commitment numbers LO-LAR-244-41, LO-LAR-244-58, and CMT891 01577 affect the Flow Accelerated Corrosion Program and, as noted in the licensee's corrective action, commitment tracking, and industry experience system (CACTIS), reside in the *associated procedure EN-DC-315. A report can be made listing the commitments for each procedure in the PCRS. This report clearly shows the commitment numbers, a concise description of the action and status, and the commitment reference numbers. These commitments previously resided in a procedure EM-09-08 "Palisades Flow Accelerated Corrosion Program," and were transferred to the new procedure, EN-DC-315. The manual for procedure EN-DC-315 contains a table for site specific commitments which clearly lists the commitments for Palisades along with the relevant sections of the procedure. Furthermore the associated procedures are added as attachments in the PCRS to verify the commitments were transferred correctly. The system for tracking commitment status and relevant procedures assist the licensee in maintaining traceability of each commitment to 'ensure commitments are not lost when relevant procedures are retired or changed.

2.3.2.5 Review to Identify Misapplied Commitments The commitments reviewed for this audit were also evaluated to determine if they had been misapplied. A commitment is considered to be misapplied if the action comprising the commitment was relied on by the NRC staff in making a regulatory decision such as a finding of publiq health and safety in an NRC safety evaluation associated with a licensing action.

Reliance on an action to support a regulatory decision must be elevated from a regulatory commitment to a legal obligation (e.g., license condition, condition of a relief request, regulatory exemption limitation or condition). A commitment is also considered to have been misapplied if the commitment involves actions that were safety significant (Le., commitments used to ensure safety).

Each of the commitments selected for the audit sample were reviewed to determine if any had been misapplied. There were no cases of misapplied commitments found in the safety evaluations issued by the NRC staff.

2.3.2.6 Review of Safety Evaluation Reports for Licensing Actions since the Last Audit to Determine if They Are Properly Captured as Commitments or Obligations In addition to the commitments selected for the audit sample, all license amendment safety evaluations, exemptions, and relief request safety evaluations that have been issued for a facility since the last audit were identified. These documents were evaluated to determine if they contained any misapplied commitments as described above. There were no cases of misapplied commitments found. The licensee had effectively captured all the commitments in their database.

2.4. 1 Audit Observations and Suggestions

1. The licensee has made a number of improvements to their commitmenttracking system since the previous commitment audit report, dated November 3, 2010. These improvements included better traceability of commitments, maintaining a single numbering system for the commitments, and implementing a change process consistent with the guidance provided in NEI 99-04.

0

(} 0 0

2. The commitment tracking system does not explicitly distinguish between commitments that are needed to restore compliance with NRC regulations and those that are voluntary (e.g. those issued for enhancements or routine corrective actions). Additionally the.

priority or level of safety significance is not distinguished for each new commitment entered into the commitment management database. According to the NEI 99-04 guidance, the.lack of distinction between varying levels of safety significance impedes the industry's objective of identifying qnd completing actions that provide the level of nuclear plant performance necessary to ensure adequate protection of public health and safety. A recommendation to evaluate and distinguish commitment priority will improve the licensee's ability to identify and track those commitments that are needed to support safety. This recommendation is aligned with the recommended actions described in NEI 99-04, Section 2.1 Managing Commitments.

3. When changing a commitment, the licensee should use a process that identifies the relative safety significance and regulatory interest of the commitment being modified.

The licensee has such a process in which a commitment change evaluation is done to document the safety significance, to determine whether the NRC should be notified, and to capture the essence for the basis for changing the commitment. The licensee should continue to document the bases for changing a commitment by completing the CCEFs which record management's review, determine if NRC notification is appropriate, and documents the safety significance of each change.

4. NRC Resident Inspectors are not usually kept informed of all the commitment chang~s, however, they do receive notification via letters on the dockets.

3.0 CONCLUSION

The NRC staff concludes that, based on the above audit, (1) Entergy has established an effective commitment management program, {2) Entergy has implemented NRC commitments on a timely basis, and (3) with some minor inconsistencies, which were discussed with the licensee during the exit meeting on November 14, 2013, Entergy has implemented an effective program for managing NRC commitment changes.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Barbara Dotson Principal Contributors: Mahesh Chawla, Jeanne Dion Date: January 17,. 2014

Attachment:

Summary of Audit Results

Item Category No.

1 LAR-Containment Type A Leak Rate Test 2

NFPA 805 3

NFPA 805 4

NFPA 805 AUDIT OF ENTERGY OPERATIONS, INC. (ENTERGY) MANAGEMENT OF REGULATORY COMMITMENTS AT PALISADES NUCLEAR PLANT PERFORMED DURING NOVEMBER 12 THROUGH NOVEMBER 14,2013 LIST OF COMMITMENTS INCLUDED IN THE AUDIT Commitment Commitment Description of Commitment Number Letter/Date LO-LAR-2011-04/06/11 PLP will use the definition in Section 5.0 of 209 04/23/12 NEI 94-01, Revision 2-A, for calculating the 2011574 Type A leakage rate.

LO-LAR-2011-11/14/08 Entergy Nuclear Operations, Inc. (ENO) will 184 11/25/08 submit a license amendment request for 06/27/11 implementation of 10 CFR 50.48©, for the Palisades Nuclear Plant (PNP), no later than December 31, 2012.

LO-LAR-2013-12/12/12 ENO will implement the new NFPA 805 fire 052 protection program at PNP, 2011486 including procedure changes, process updates, and training of the affected personnel as identified in Attachment S, Table S-3, within six months after NRC approval, or six months after a refueling outage if in progress at the time of approval.

LO-LAR-2013-12/12/12 ENO will complete implementation of the 052 modifications in Attachment S, Table S-2, at 2011487 PNP before the end of the second full operating cycle after NRC approval.

Appropriate compensatory measures will be Status Closed Closed Open Open ADAMS Accession No. ML110970616 ML120740081 ML083400226 ML083370155 ML111790133 ML12348A455 I

I Attachment Item Category Commitment Commitment Description of Commitment Status ADAMS No.

Number Letter/Date Accession No.

maintained until modifications are complete.

5 LER 2011-004 No PCRS Item -

07/08/11 ENO will provide a supplement containing the Closed ML111890417 Reg Horizons results of the additional causal evaluation and Only potential new corrective actions by December 2011576 15, 2011.

6 Relief Request LO-LAR-2012-04/26/12 Entergy will perform appropriate actions to Open ML12118A144 291 04/30/12 meet ASME Section XI Code Case N-770-1 ML121230295 2011473 05/01/12 baseline examinations for those dissimilar ML12123A079 09/26/12 metal welds not meeting the examination ML12258A352 12/11/12 coverage requirements during the 2012 ML12347A158 refueling outage prior to startup from the planned fall 2013 refueling outage. These actions include:

1) compliance with N-770-1 requirements, or

2) removal of the subject locations from the scope of ASME Section XI Code Case N-770-1, or

3) submittal of relief request in accordance with the applicable provisions of 1 0 CFR 50.55a.

REVISED COMMITMENT: Entergy will perform appropriate actions to meet ASME Section XI Code Case N-770-1 baseline examinations for those dissimilar metal welds not meeting the examination coverage requirements during the 2012 refueling outage prior to startup from the planned fall 2013 refueling outage. These actions include:

1) compliance with N-770-1 requirements, or

2) removal of the subject locations from the Item Category Commitment Commitment Description of Commitment Status ADAMS I

No.

Number Letter/Date Accession No.

scope of ASME Section XI Code Case N-770-1.

7 SIRWTCAL LO-LAR-2012-07/12/12 On July 12, 2012, Entergy submitted a letter ML12194A573 211 07/17/12 to the NRC titled, "Safety Injection Refueling ML12199A409 2011469 6/20/13 Water Tank Leakage and Corrective Actions."

2011470 The letter made five commitments. After 2011471 discussion with the NRC, it was agreed that 2011472 they would be issuing a Confirmatory Action I

2011475 Letter that would revise some of the commitments made in the July 12, 2012 letter. On July 17, 2012, the NRC issued, "Confirmatory Action Letter - Palisades Nuclear Plant Commitments to Address Safety Injection Refueling Water Tank and Control Room Concrete Support Structure Leakage." The following commitments were made in the July 17, 2012 letter:

Closed

1) ENO will measure and trend leakage daily from the SIRWT in accordance with the approved Operation DeCision-Making Issue (ODMI) document until such a time as the SIRWT is no longer classified as degraded/nonconforming for this adverse condition. The degradation growth rate will be calculated to determine the need for future SIRWT inspections. END will re-perform the growth rate calculation periodically, depending on changes in the observed leakage rate: This commitment is tied to SIRWT ODMI by commitment number Closed 2011469.

i Item Category Commitment Commitment Description of Commitment Status ADAMS No.

Number Letter/Date Accession No.

2) ENO will declare the SIRWT inoperable and shut down the plant, as required by Closed Technical Specifications, prior to, or upon reaching:

a. the ODMI calculated leakage rate of 38 gallons per day from the SIRWT or;

b. the predicted time allowed (Tallow defined in American Society of Mechanical Engineers (ASME) Code Case N-705, ?Evaluation Criteria for Temporary Acceptance of Degradation in Moderate Energy Class 2 or 3 Vessels and Tanks,? dated October 12, I

I 2006), at which the detected degradation will I

grow to the _maximum structurally allowable size, becomes less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. ENO will i

I notify the NRC prior to changing any of the limits specified in the above criteria. NRC staff will not provide concurrence on the Open proposed limit change. This commitment is tied to SIRWT ODMI by commitment number 2011470.

3) If monitoring determines that the SIRWT is actively leaking, ENO will take appropriate actions to repair the tank within 26 months of Open the identification of the leak, as specified by ASME Code Case N-705. This commitment is tied to SIRWT ODMI by commitment number 2011471.

Item Category Commitment Commitment Description of Commitment Status ADAMS No.

Number Letter/Date Accession No.

4) ENO will continue inspections of the concrete support structure above the control room, control room hallway, and the concrete support structure ceiling as prescribed in the approved ODMI. These inspections are to ensure that the temporary modifications Open installed to prevent impact to safety-related structures, systems and components are performing their intended functions. This commitment is tied to SIRWT ODMI by commitment number 2011472.

5) ENO will correct the adverse condition related to cracking of the concrete support structure around the ceiling of the control room, which could lead to water intrusion, prior to restart from the 2013 refueling.

Open outage. This action is being tracked under CA1 of this LAR. Reference 2011475.

Letter dated 6/20/13 closed commitments 1, 2 and 3. The letter revised commitments 4 to note that the inspections will be in accordance with an Operations Standing Order. The ODMI was closed.

Commitment number 5 was revised to note that the condition will be corrected during the next refueling outage vs. the 2013 refueling outage since the scheduled outage may move into 2014.

8 LAR-LO-LAR-2012-09/06/12 ENO will establish the Technical Specification Open ML12250A814 Item Category Commitment Commitment Description of Commitment Status ADAMS No.

Number Letter/Date Accession No.

Snubbers 238 03/29/13 (TS) Bases for Limiting Condition for ML13064A140 2011575 Operation (LCO) 3.0.8 as adopted with the applicable license amendment.

9 Relief Request N/A 10/30/12 Three commitments made in 10/30/1-2 Closed ML12305A362 SWS Manual submittal were subsequently withdrawn in ML12347A159 Valve letter dated 12/11/12 when the valve for which relief was requested was replaced.

10 Fukushima LO-LAR-2013-See Table See Table Open 137 See Table 11 GSI-191 LO-LAR-2012-05/15/2013 ENO will meet with the NRC, as soon as Closed ML13136A006 206 practical after May 16, 2013, to discuss this ML13247A697 2011599 proposed resolution path.

2011600 2011601 ENO will complete measurements for 2011602 insulation replacement. Due by the end of Open 2011603 the first refueling outage following January 1, 2011604 2013.

ENO will submit a schedule for completion of the risk-informed resolution path activities that provides for submittal of a licensing action following issuance of a safety evaluation (SE) for the South Texas Project (STP) license amendment request (LAR). Due by December 31, 2013.

Open ENO will complete any necessary insulation replacements or remediation or other identified plant changes. Due during the refueling outage that follows issuance of a SE for the risk-informed resolution LAR for Item Category Commitment Commitment Description of Commitment Status ADAMS No.

Number Letter/Date Accession No.

Palisades Nuclear Open Plant (PNP).

ENO will submit a final updated supplemental re~ponse to support closure of GL 2004-02 for PNP. Due within six months of receipt of Open the SE for the risk-informed resolution LAR for PNP.

If it is determined during the risk-informed process that this option is not viable, ENO will complete a deterministic resolution path that I

is acceptable to the NRC. Due within two refueling outages after the issuance of the SE for the STP LAR.

12 License LO-LAR-2011-8/25/05 3/31/11: ENO will submit a revised program Closed ML052410206 Renewal 166 3/23/09 plan for aging management of reactor vessel ML090830419 Reactor 2011479 3/10/10 internals within a year of the issuance of the ML100710083 Vessel 3/31/11 final NRC safety evaluation for MRP-227.

ML110910461 Internals 6/20/12 ML12173A219 Program 9/13/12 6/20/12: ENO will submit a revised program ML12257A352 plan for aging management of reactor vessel internals, for PNP, in accordance with MRP-227-A.

13 License LO-LAR-2012-4/2/12 4/2/12: Provide response to Request for Closed ML12068A388 Renewal 110 5/31/12 Additional Information within 60 days ML12153A114 Alloy 600 2011478 8/15/12 ML12206A076 Program 14 License LO-LAR-2009-9/3/10 See table attached to letter for a description Closed ML102630234 Renewal 244-7 of each commitment change.

Revision of 2011581 Commitments LO-LAR-2009-Item Category Commitment Commitment Description of Commitment Status ADAMS No.

Number Letter/Date Accession No.

244-23 2011419 LO-LAR-2009-244-262011422 LO-LAR-2009-244-39 2011431 LO-LAR-2009-244-42 LO-LAR-2009-244-43 2011588 15 License r

LO-WTPLP-12/20/10 Entergy Nuclear Operations, Inc. (ENO) will Closed Ml110060692 Renewal 2010-535 02/01/12 perform a volumetric inspection of the reactor ML12033A037 PTS LO-LAR-2009-vessel beltline region welds during the 2012 244-75 refueling outage.

2011578 Open LO-LAR-2009-Revised by Letter 2/1/12: Entergy Nuclear 244-76 Operations, Inc. (ENO) will perform a 2011577 volumetric inspection of the reactor vessel beltline region welds during the 2013 Open refueling outage.

ENO will transmit a revised pressurized thermal shock evaluation under 10 CFR 50.61 a, including an evaluation of near-surface flaws from the volumetric examination, for review and approval no less than three (3) years before the reactor vessel limiting axial welds fabricated with weld wire heat no. W5214 are projected to reach the PTS screening criterion cited under 10 CFR Item Category Commitment Commitment Description of Commitment Status ADAMS No.

Number Letter/Date Accession No.

50.61.

Revised by Letter 2/1/12: Entergy Nuclear Operations, Inc. (ENO) will perform a volumetric inspection of the reactor vessel beltline region welds during the 2013 refueling outage.

16 License LO-LAR-2009-1/19/11 Provides notification that commitment is Closed ML110190547 Renewal 244-4 closed: "NMC will evaluate the effect the Completion of 2011579 increase in variable speed charging pump Charging Line out-of-service events may have on these Evaluation lines (Charging Lines Inboard of the Regenerative Heat Exchanger), and will take actions necessary to ensure these lines meet licensing basis design criteria for the extended operating period. NMC will complete this evaluation and will advise the NRC of the results, and of any necessary corrective actions, before the end of the current licensed operating period."

17 License LO-LAR-2009-3/23/11 License Condition 2.1 required that the NRC Closed ML110830011 Renewal 244-2 be notified in writing when implementation of Completion of 2011578 activities was complete for verification by Activities to NRC inspection.

Support Entry I

Into the Period The letter provides notification that of Extended commitments required prior to entry into the I

Operation PEO were completed and that the commitment to submit an equivalent margins analysis remains open.

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) 415-8371.

Docket No. 50-255

Enclosure:

Audit Report cc w/encl: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL 3-1 r/f RidsNrrDorllpl3-1 Resource RidsNrrPMPalisades Resource RidsNrrLAMHenderson Resource RidsOgcMaiiCenter Resource RidsAcrsAcnw_MaiiCTR Resource JBenjamin, Rill ACRS TTaylor, Rill AScarbeary, Rill RidsRgn3MaiiCenter Resource ADAMS Accession Number: ML14006A306 OFFICE LPL2-2/PM LPL3-1/PM NAME JDion MChawla DATE 01/09/14 01/15/14 Sincerely,

/RAJ Mahesh Chawla, Project Manager Plant Licensing Branch 111-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation LPL3-1/LA LPL3-1/BC MHenderson RCa rison 01/15/14 01/17/14 OFFICIAL RECORD COPY

/