ML14027A618

Audit of the Licensees Management of Regulatory Commitments

ML14027A618
Person / Time
Site:	Kewaunee
Issue date:	12/23/2014
From:	Michael Orenak Plant Licensing Branch IV
To:	Heacock D Dominion Energy Kewaunee
Benney B
References
TAC MF3524
Download: ML14027A618 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

lnnsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 December 23, 2014 SUBJECT KEWAUNEE POWER STATION - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MF3524)

Dear Mr. Heacock:

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 Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented. An audit of the commitment management program for Kewaunee Power Station (KPS) was performed during the period of December 3, 2013, through December 23, 2013. The previous audit of the licensee's commitment management program for KPS was documented in an NRC letter dated April 11, 2011.

As discussed in the enclosed audit report, the NRC staff concludes that the licensee's procedure used to manage commitments contains the necessary attributes for an effective commitment management program. The NRC staff also finds that the commitment management procedure is adequate and effective in managing regulatory commitments for KPS.

The NRR staff has discussed the results of this audit with NRC Region Ill staff. Any follow-up on the issues discussed in the audit report may be considered during future inspection activities.

If you have any questions, please contact me at (301) 415-3229.

Docket No. 50-305

Enclosure:

Audit Report cc w/encl: Distribution via Listserv Sincerely,

~/Jv~

Michael D. Orenak, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION DOCKET NO. 50-305

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 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML003741774), 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. 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 defines a "regulatory commitment" as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees' commitment management programs once every 3 years to determine whether the licensees' programs are consistent with the industry guidance in NEI 99-04, and that the regulatory commitments are being effectively implemented. 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 (e.g., amendments, reliefs, exemptions) and activities (e.g., responses to bulletins or generic letters).

An audit of the commitment management program for Kewaunee Power Station (KPS) was performed during the period of December 3, 2013, through December 23, 2013. The audit was performed at NRC Headquarters in Rockville, Maryland using documentation provided by Dominion Energy Kewaunee, Inc. (DEK, the licensee), as requested by the NRC staff. The previous audit of the licensee's commitment management program for KPS was documented in an NRC letter dated April 11, 2011 (ADAMS Accession No. ML101550684).

Enclosure 2.0 AUDIT PROCEDURE AND RESULTS The audit was performed in accordance with the guidance in NRR Office Instruction LIC-105, Revision 5, "Managing Commitments Made by Licensees to the NRC," dated September 16, 2013 (ADAMS Accession No. ML13193A358).

The NRC staff reviewed commitments made during the 3 year period following the last audit, specifically, from August 1, 2010, through November 1, 2013. 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 were correctly applied.

2.1 Verification of Licensee's Implementation of 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 and activities. For commitments not yet implemented, the NRC staff determines whether the commitments 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 changes proposed in the future 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 made as a result of licensing actions or in response to other NRC communications (e.g., bulletins, generic letters, etc.). Before the audit, the NRC staff performed a search in ADAMS to obtain a list of licensing action requests and other regulatory documents submitted since the last audit so that a representative sample could be used for the audit. The commitments included in the review are shown in Table 1.

The audit excluded the following types of commitments:

(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, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.

2.1.2 Audit Results Table 1 provides the details and results of the audit for verification of the licensee's implementation of commitments. The audit included commitments that had been completed, and commitments that had yet to be implemented. The NRC staff's review of the closed commitments found that the commitments were implemented within their respective due dates.

The NRC staff did not identify any deficiencies during its review of the implementation of commitments.

The NRC staff noted that, because of the licensee's decision to decommission the reactor, several commitments associated with systems, structures, and components that are no longer in use have not been implemented. The staff's review of those commitments found no safety impact. The NRC staff expects that the licensee will review all outstanding commitments and modify or delete the commitments in the future, as appropriate, using the commitment change process.

In the course of the review, two commitments were identified for which successful completion depended on external resources. Table 4 documents the staff's review of these two commitments. In the first commitment, a fleet document control process managed by Dominion Nuclear documented the successful completion of a KPS commitment. The NRC staff reviewed Dominion Nuclear's fleet document control processes and found it contained attributes that protected KPS-specific content from unintended revision. The second commitment involves updating a Letter of Agreement with a nearby licensee regarding the sharing of mitigating strategies equipment. The implementation of the second commitment was in progress.

2.2 Verification of the Licensee's Program for Managing Changes to NRC Commitments The NRC staff verified that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The staff compared the licensee's process for controlling regulatory commitments to the guidelines in NEI 99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at KPS is contained in Dominion procedure LI-AA-11 0, Revision 0, "Commitment Management."

The audit included a sample of commitment changes, documented in Table 2, that have been or will be reported to the NRC.

2.2.1 Audit Results The NRC staff reviewed the licensee's procedure LI-AA-110, Revision 0, against NEI 99-04.

Section 5.4 of the procedure lists NEI 99-04 as a reference.

The NRC staff found that the process described in LI-AA-11 0 generally follows the guidance of NEI 99-04 and provides detailed instructions for:

(1) making and identifying commitments; (2) tracking commitments; (3) annotating implementing documents to provide traceability of commitments; (4) changing commitments; and (5) periodic reporting of commitment changes.

The NRC staff concludes that the administrative controls for modifying or deleting commitments made to the NRC used by the licensee were effective based on a review of a sample of commitment changes.

Even though the licensee did not process any commitment changes during the audit period, the NRC staff reviewed older commitment changes not previously reviewed by the staff to verify the administrative controls for modifying commitments were effective. Table 2 provides the specific details and results of the audit of commitment changes for KPS. The audit did not identify any deficiencies.

It is noteworthy, however, that all changes reviewed were originated prior to 1996. For older commitments such as these, the licensee used a system, Comtrak, which did not have the ability to document the commitment change justification. The new system, Central Reporting System (CRS), does have the capability to document commitment change justification. The licensee stated that no commitments older than 2010 were still open within the CRS, so for future commitment changes, the justification for the change will be documented within the commitment management system.

2.3 Verification That All Regulatory Commitments Were Correctly Applied On September 19, 2011, the NRC's Office of the Inspector General (OIG) issued an audit report entitled, "Audit of NRC's Management of Licensee Commitments" (ADAMS Accession No. ML112620529). The audit report identified, in part, that the definition and use of commitments is not consistently understood throughout the NRC. The OIG concluded that this could potentially result in the misapplication of commitments by the NRC staff. A commitment is considered to be misapplied if: (1) the action comprising the commitment was relied on by the NRC staff in making a regulatory decision such as those affecting public health and safety in an NRC safety evaluation (SE) associated with a licensing action, or (2) the commitment involves actions that were safety significant (i.e., commitments used to ensure safety).

As one of the corrective actions taken in response to the issues raised in the OIG audit, the NRC staff added further guidance on proper use of regulatory commitments in NRR Office Instruction LIC-1 01, Revision 4, "License Amendment Review Procedures," dated May 25, 2012 (ADAMS Accession No. ML113200053). As stated in Section 4.4.1 of LIC-1 01, staff SEs may rely on a commitment if the commitment is escalated into an obligation (for example, incorporation into a license condition or technical specification requirement) or is subsequently incorporated into a mandated licensing basis document such as the Updated Safety Analysis Report). In cases where a commitment has been escalated to an obligation or incorporated into a mandated licensing basis document, the "commitment" is no longer considered a commitment and is no longer subject to change via the licensee's commitment management program since other regulatory processes would govern the change (e.g., Title 10 Code of Federal Regulations) (10 CFR) 50.90, or 10 CFR 50.59).

Another corrective action taken in response to the issues raised in the OIG audit included further guidance, concerning performance of commitment audits, being added in LIC-105.

Revision 5 of LIC-1 05 states that the NRC staff should take the following actions to identify misapplied commitments:

1) Determine if the commitment reviewed involves actions that were safety significant (i.e., commitments used to ensure safety).

2) Determine if the commitment reviewed involves actions that were necessary for approval of a proposed licensing action.

The NRC staff reviewed each of the commitments sampled for this audit to determine if any commitment had been misapplied (per the criteria shown above). Table 3 lists each of these licensing actions for KPS.

2.3.1 Table 1 -Verification of Licensee's Implementation of NRC Commitments Table 1 summarizes the licensee's implementation of commitments as assessed from 15 samples. If the NRC relied on the commitment and the commitment has already been implemented, then no further action would be required. If the commitment has not been implemented, further action would need to be evaluated. With the exception of Amendment 207, "Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond Scope Issues," dated February 2, 2011 (ADAMS Accession No. ML102020662), the NRC staff did not rely on any of the commitments examined for this audit in their SEs. Amendment 207, "Issuance of Amendment for the Conversion to the Improved Technical Specifications with Beyond Scope Issues," dated February 2, 2011 (ADAMS Accession No. ML102020662), was issued in response to license amendment request (LAR) 255. Table 1 shows that all LAR 255 commitments are either completed or have been incorporated into the USAR where any future changes to the commitments are controlled under 10 CFR 50.59.

2.3.2 Table 2 -Verification of the Licensee's Program for Managing NRC Commitment Changes In Table 2, the NRC staff documents its review of the licensee's program for managing commitment changes. The staff sampled six commitment changes. The NRC staff found that Comtrak and its successor, the CRS, managed the six commitment changes in accordance with the program guidance. The staff's review did not identify any instance where a commitment change affected an NRC staff SE that considered the original commitment.

2.3.3 Table 3-Review of NRC License Amendments and Relief Requests The NRC staff reviewed the licensing actions in Table 3, which included license amendments and relief requests. Seven samples in the interval from February 2, 2011, to May 3, 2012, were reviewed. Four of the licensing actions contained a total of 29 commitments. The staff's review of the commitments found that they were used properly, in that if a commitment was used to ensure safety, or described an action that was necessary for the approval of the associated licensing action, the commitment was elevated to an obligation or transferred to a mandated licensing basis document.

During the audit, the NRC staff identified one instance, for Amendment 207 in Item 1 of Table 3, where commitments were relied upon by the NRC, as documented in the staff's SE. In Sections 4.D and 4.E of theSE, the staff relied upon the relocation of certain technical specifications and operating license conditions, if applicable, to other licensee-controlled documents. A license condition capturing the commitment was added to the license, elevating the commitments to obligation status. The NRC staff's review of Item 1 as part of this audit determined that the commitments had been properly elevated to obligations in this instance, as they had been relied upon for approval of a proposed licensing action.

3.0 CONCLUSION

The NRC staff concludes based on the results of the audit discussed above that: (1) KPS has implemented NRC commitments on a timely basis, and (2) KPS was implemented an effective program for managing commitments and changes to commitments.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT MaryJo Haese Richard P. Reps has Principal Contributors: M. Orenak C. Gratton Date: December 23, 2014 Attachments:

1. Table 1 -Verification of Licensee's Implementation of NRC Commitments

2. Table 2-Verification of the Licensee's Program for Managing NRC Commitment Changes

3. Table 3-Review of NRC License Amendments, Relief Requests and Exemptions

4. Table 4-Verification of Effective External Coordination for Managing NRC Commitment Changes

Item Licensee Submittal No.

(ADAMS Ace. No.)

1 Letter dated 7/12/10 (ML102010091) 2 Letter dated 8/18/1 0 (ML102371197) 3 Letter dated 8/18/10 (ML102371197)

TABLE 1 Verification of licensee's Implementation of NRC Commitments (See Note 1)

Subject Commitment as stated in Licensee Commitment Status and Audit Sample Submittal (Licensee Tracking No.)

Item Disposition Results in accordance with NEI 99-04 and Licensee's Procedures? {Yes/No) in boldface Kewaunee & Millstone, Units 2 Establish Cyber Security Assessment Per creation of procedure IT-AA-CYB-

& 3 and North Anna & Surry, Team.

105 and assembly of cyber security Units 1 & 2 - Supplement to assessment team, the commitment Request for Approval of the was closed.

Cyber Security Plan.

Yes License Amendment Request DEK will have written procedures Per modification of procedure OP-KW-249: Kewaunee Conversion to available describing the AOP-GEN-005, the commitment was Improved Technical compensatory measures when LCO closed.

Specifications 3.7.1 0, Control Room Post-Accident Recirculation (CRPAR) System, Yes ACTION B, "Two CRPAR trains inoperable due to inoperable control room boundary in MODE 1, 2, 3, or 4," is entered.

License Amendment Request DEK will ensure that when LCO Per modification to procedure MA-KW-249: Kewaunee Conversion to 3.0.8b is used, appropriate plant MSP-HSS-001, the commitment was Improved Technical procedures and administrative closed.

Specifications controls are revised to implement the following Tier 2 Restriction: At least Yes one AFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), or some alternative means of core cooling (e.g., F&B, firewater system or "aggressive secondary cooldown" using the steam generators) must be available.

Item Licensee Submittal Subject Commitment as stated in Licensee Commitment Status and Audit Sample No.

(ADAMS Ace. No.)

Submittal (Licensee Tracking No.)

Item Disposition Results in accordance with NEI 99-04 and Licensee's Procedures? (Yes/No) in boldface 4

Letter dated 8/18/10 License Amendment Request DEK will revise the USAR or TS DEK revised the TS Bases and USAR (ML102371197) 249: Kewaunee Conversion to Bases to describe the restrictions in to describe the restrictions.

Improved Technical commitments 3 and 4.

Specifications Yes 5

Letter dated 8/18/10 License Amendment Request 8.Withdrawn, refer to Enclosure DEK stated the commitment described (ML102371197) 249: Kewaunee Conversion to Volume 8 (KAB-077) a process that was already contained Improved Technical within Dominion fleet procedures and Specifications separate procedures would be redundant. Staff found the reasoning to be adequate.

Yes 6

Letter dated 8/18/10 License Amendment Request DEK commits to change (or verify)

Per the creation of procedure MA-KW-(ML102371197) 249: Kewaunee Conversion to procedure(s) to include the measuring ESP-EDC-003, the commitment was Improved Technical and test equipment manufacturer's closed.

Specifications recommended practice for instrument stabilization when measuring float Yes current to confirm battery state of charge. (GMW-014) 7 Letter dated 8/18/10 License Amendment Request DEK has committed in the GL 2008-This commitment is outstanding, but (ML102371197) 249: Kewaunee Conversion to 01 letter to monitor the status of the currently in process for closure due to Improved Technical industry/NRC Technical Specification the permanent shut down of Specifications Task Force (TSTF) Traveler to be Kewaunee.

developed as a follow-up to GL 2008-

01. Following NRC approval of this Yes TSTF, DEK will adopt applicable portions of the Traveler. (MEH-002) 8 Letter dated Response to RAI Regarding The Bolting Integrity Program will be Commitment is no longer needed due 9/5/2013 License Amendment Request enhanced to further incorporate to the permanent shut down of (ML13254A186) 255: Deletion of License applicable Electric Power Research Kewaunee. The licensee provided Renewal Condition for Institute (EPRI) and industry bolting adequate justification within the CRS.

Permanently Defueled License guidance. Topic enhancements will The licensee transferred the include proper joint assembly, torque commitment to Section 15.7 of the Item Licensee Submittal Subject Commitment as stated in Licensee Commitment Status and Audit Sample No.

(ADAMS Ace. No.)

Submittal (Licensee Tracking No.)

Item Disposition Results in accordance with NEI 99-04 and Licensee's Procedures? (Yes/No) in boldface values, gasket types, use of USAR for management under 1 0 CFR lubricants, and other bolting 50.59.

fundamentals.

Yes 9

Letter dated Response to RAI Regarding The Buried Piping and Tanks Licensee performed the inspections 9/5/2013 License Amendment Request Inspection program will be enhanced ahead of schedule and an NRC (ML13254A186) 255: Deletion of License to perform visual inspections of a inspection verified the adequacy of the Renewal Condition for representative sample of inspection. The licensee transferred Permanently Defueled License material/protective measure the commitment to Section 15.7 of the combinations for in-scope buried USAR for management under 1 0 CFR piping and tanks.

50.59.

The following materials are utilized in buried applications with the Yes associated protective measures:

• Steel (including cast iron)/coated,

• Steel/coated and wrapped,

• Steel/uncoated, and

• Stainless steel/coated and wrapped Visual inspections of the external surfaces of the components will be performed to identify damaged wrapping (if present), degraded or damaged coating (if present), and evidence of loss of material. Each piping inspection will include a minimum of 10 linear feet of piping.

The following inspections will be performed:

-The circulating water system 30- inch diameter recirculation line, which is coated and wrapped carbon steel, will receive one inspection prior to the period of extended operation, and additional inspections within the first 1 0 years and second 1 0 years of the Item Licensee Submittal Subject Commitment as stated in Licensee Commitment Status and Audit Sample No.

(ADAMS Ace. No.)

Submittal (Licensee Tracking No.)

Item Disposition Results in accordance with NEI 99-04 and Licensee's Procedures? (Yes/No) in boldface i

period of extended operation.

- The circulating water system recirculation line vent piping, which is coated and wrapped stainless steel, will receive one inspection prior to the period of extended operation and additional inspections within the first 1 0 years and second 1 0 years of the period of extended operation.

i

-The diesel generator system fuel oil piping, which includes coated and wrapped carbon steel fuel oil supply and return piping, storage tank vent piping, and day tank vent piping, will receive one inspection prior to the period of extended operation and additional inspections within the first 1 0 years and second 1 0 years of the period of extended operation. The inspections will be performed in the non-cathodically protected portion of the piping. The diesel generator system fuel oil storage tanks, which are coated carbon steel, will receive one inspection of one tank prior to the period of extended operation. An additional tank inspection will be performed within each of the first and second 1 0 years of the period of extended operation.

-The diesel generator system fuel oil storage tanks hold down straps, which are uncoated carbon steel, will be inspected in conjunction with the associated fuel oil storage tank Item Licensee Submittal Subject Commitment as stated in Licensee Commitment Status and Audit Sample No.

(ADAMS Ace. No.)

Submittal (Licensee Tracking No.)

Item Disposition Results in accordance with NEI 99-04 and Licensee's Procedures? (Yes/No) in boldface inspection. One set will be inspected prior to the period of extended operation, and one set will be inspected within each of the first and second 1 0 years of the period of extended operation. The fire protection system piping, which is coated ductile iron, will receive three inspections prior to the period of extended operation, and three additional inspections within each of the first and second 1 0 years of the period of extended operation.

10 Letter dated Response to RAI Regarding The Structures Monitoring Program Program enhancement complete. The 9/5/2013 License Amendment Request will be enhanced to monitor licensee transferred the commitment (ML13254A186) 255: Deletion of License groundwater quality and verify that it to Section 15.7 of the USAR for Renewal Condition for remains non-aggressive to below-management under 10 CFR 50.59.

Permanently Defueled License grade concrete.

Yes 11 Letter dated Response to RAI Regarding Quarterly laboratory testing of fuel oil DEK Licensee edited their procedure 9/5/2013 License Amendment Request samples for water, sediment, and and has work orders in place to (ML13254A186) 255: Deletion of License particulates will be performed on the continue performing the commitment.

Renewal Condition for EDG day tanks and on the technical The licensee transferred the Permanently Defueled License support center diesel generator (TSC commitment to Section 15.7 of the DG) day tank. The testing acceptance USAR for management under 10 CFR criteria will be consistent with the 50.59.

requirements specified in American Society for Testing and Materials Yes (ASTM) D975-06b for water and sediment and ASTM D6217 for particulates.

12 Letter dated Response to RAI Regarding At least one core bore sample will be Commitment complete. Monitoring of 9/5/2013 License Amendment Request taken from the waste drumming room the spent fuel pool structure is (ML13254A186) 255: Deletion of License reinforced concrete ceiling below the performed under 10 CFR 50.65 Renewal Condition for spent fuel pool. The core sample Maintenance Rule. The licensee Item Licensee Submittal Subject Commitment as stated in Licensee Commitment Status and Audit Sample No.

(ADAMS Ace. No.)

Submittal (Licensee Tracking No.)

Item Disposition Results in accordance with NE199-04 and Licensee's Procedures? (Yes/No) in boldface Permanently Defueled License location and depth will be sufficient to transferred the commitment to validate the strength of the concrete Section 15.7 of the USAR for and the extent of any degradation.

management under 10 CFR 50.59.

The core sample will be tested for compressive strength and will be Yes subject to petrographic examination.

Reinforcing steel in the core sample area will be exposed and inspected for material condition.

13 Letter dated Response to RAI Regarding Develop an action plan for Per completion of procedure ETE-KW-9/5/2013 License Amendment Request identification and remediation of spent 2011-035, commitment is complete.

(ML13254A186) 255: Deletion of License fuel pool (SFP) liner leakage to be Monitoring of the spent fuel pool Renewal Condition for implemented during the period of structure is performed under 10 CFR Permanently Defueled License extended operation.

50.65 Maintenance Rule. The licensee transferred the commitment to Section 15.7 of the USAR for management under 10 CFR 50.59.

Yes 14 Letter dated Response to RAI Regarding A surveillance program will be Commitment is open. Scheduled 9/5/2013 License Amendment Request implemented to perform verification completion date is 2017. The licensee (ML13254A186) 255: Deletion of License that the Boral spent fuel storage rack transferred the commitment to Section Renewal Condition for neutron absorber 8-10 areal density 15.7 of the USAR for management Permanently Defueled License is maintained within the bounds of the under 10 CFR 50.59.

spent fuel pool criticality analysis.

Yes 15 Letter dated Response to RAI Regarding The Structures Monitoring Program The Structures Monitoring Program 9/5/2013 License Amendment Request will be revised to include the was revised. Commitment is (ML13254A186) 255: Deletion of License evaluation criteria of ACI 349.3R-96, complete. Monitoring of the spent fuel Renewal Condition for Chapter 5, as the criteria to be used pool structure is performed under 10 Permanently Defueled License when evaluating conditions or findings CFR 50.65 Maintenance Rule. The identified during concrete structure licensee transferred the commitment inspections. This will be done prior to Section 15.7 of the U SAR for to the performance of the next management under 10 CFR 50.59.

scheduled inspection, which will Item Licensee Submittal Subject Commitment as stated in Licensee Commitment Status and Audit Sample No.

(ADAMS Ace. No.)

Submittal (Licensee Tracking No.)

Item Disposition Results in accordance with NEI 99-04 and Licensee's Procedures? (Yes/No) in boldface Yes occur prior to the period of extended operation Note 1: The scope of this portion of the audit includes verification of the licensee's implementation of commitments associated with NRC licensing actions (e.g., amendments, relief requests, exemptions, orders) or licensing activities (e.g., bulletins, generic letters) during the previous 3 years. For purposes of this audit, the scope included samples based on review of licensee submittals dated August 1, 2010 through November 1, 2013. See Audit Report Section 2.1.1 for further details.

Item No.

1 2

Licensee TABLE 2 Verification of the Licensee's Program for Managing NRC Commitment Changes (See Note 1)

Description of Commitment Change Audit Results -Verification of Tracking No.

Licensee's Program for Managing Commitment Changes94-161 On May 5, 1988, the NRC issued Bulletin (BL) 88-04 Commitment is closed in the Comtrak system.

(Reference 1 ), concerning potential safety-related pump loss. Wisconsin Public Service Corporation (WPSC), then This older commitment tracking system, Comtrak, licensee for Kewaunee Power Station (KPS) submitted a did not provide a location to attach/describe an response to BL 88-04 on November 8, 1994 (Reference explanation for the changes; however, licensee 9). In the response, WPSC committed to performing provided an explanation in their letter dated June 3, disassembled inspections of the safety injection (SI) 2010. Since the Comtrak system is not in use pumps every 15 years to ensure no damage is occurring anymore and the new system, Central Reporting as a result of operation on minimum flow recirculation.

System, provides ample room for explanation, the added traceability enhances management of Based on an evaluation documented in reference 1 0, regulatory commitments.

Dominion Energy Kewaunee, Inc. (DEK) revised the periodicity of the inspection commitment for Sl pump 1 A Sample verifies that commitment changes are from 15 years to 16.5 years.

being managed successfully.

However, due to delays in obtaining a spare rotating assembly prior to the fall 2009 refueling outage (KR-30),

DEK deferred the disassembled inspections to the next refueling outage (KR-31 }, which is scheduled to begin February 2011. In support of this deferral, in September 2009, DEK completed an additional evaluation to justify extending the periodicity of disassembled Sl pump inspections to 18 years.

Accordingly, DEK revised the commitment for inspecting Sl pumps to an 18-year interval.

For conservatism, in March 2010 DEK subsequently revised the commitment to perform disassembled inspections of the Sl pumps to state that the 18-year interval will only apply to a single inspection period, followed by a return to the originally committed 15-year intervals.

LA001218 DEK will take actions needed to eliminate gas Commitment is closed. The licensee performed the accumulations that were found during UT examinations of actions as described.

subject systems. The actions to be taken are still in Item Licensee Description of Commitment Change Audit Results -Verification of No.

Tracking No.

Licensee's Program for Managing Commitment Changes development, but are expected to include some combination of installation of additional vent valves and Sample verifies that commitment changes are procedure modifications to ensure systems are sufficiently being managed successfully.

filled after draining for maintenance. Alternatively, DEK may choose to revise design basis documents to establish new allowable design basis limits on gas accumulation.

The locations where gas accumulations were found that will be corrected include:

• Train A ICS discharge piping near the containment penetration

• Train A ICS discharge piping branch line associated with the full flow test line

• Caustic addition branch line to the ICS suction piping

• CVCS-RHR cross-connect piping from the RHR discharge piping

• RHR-to-Spent Fuel Pool interconnection branch line from the RHR discharge piping

• Train A RHR mini-flow recirculation branch line from the RHR discharge piping

• Sl test line branch from the Sl discharge piping

• Suction bypass branch to the Sl suction piping

• RHR normal cooldown suction line from RCS loop A.

Schedule: Complete prior to the end of the next Refueling Outage KR 30 (fall of 2009).

From the above list, the following voids have not been eliminated or accepted by revision to design basis analysis:

• CVCS-RHR cross-connect piping from the RHR discharge piping

• RHR-to-Spent Fuel Pool interconnection branch line from the RHR discharge piping

• Suction bypass branch to the Sl suction piping The revised commitment description states:

1. DEK will take actions needed to resolve the gas accumulations at the following locations:

• CVCS-RHR cross-connect piping from the RHR Item Licensee Description of Commitment Change Audit Results -Verification of I

No.

Tracking No.

Licensee's Program for Managing Commitment Changes discharge piping

• Suction bypass branch to the Sl suction piping

• RHR-to-Spent Fuel Pool interconnection branch line from the RHR discharge piping Resolution may include installation of additional vent valves, procedure modifications to ensure systems are sufficiently filled after draining for maintenance, or revision of design basis documents to establish new allowable design basis limits on gas accumulation. These actions, originally scheduled to be completed by the end of refueling outage KR 30, will be completed by the end of refueling outage KR 31 (spring of2011).

3 83-142 In the first letter, KPS committed to periodic inspections of Commitment is closed in the Comtrak system.

containment by the Plant Manager or one of his direct reports. This was in response to an event in 1982 wherein This older commitment tracking system, Comtrak, all Containment Pressure instrument sensing lines inside did not provide a location to attach/describe an containment were found capped, thereby rendering them explanation for the changes; however, licensee inoperable. It was stated that this action would "... keep the provided an explanation in their letter dated May 29, plant management informed of the condition of the plant."

2010. Since the Comtrak system is not in use anymore and the new system, Central Reporting In the second letter, KPS responded to a request for System, provides ample room for explanation, the confirmation that a program was in place to ensure that added traceability enhances management of boric acid corrosion would not lead to degradation of the regulatory commitments.

RCS pressure boundary. KPS cited management inspections of containment as a component of this Sample verifies that commitment changes are program.

being managed successfully.

Item Licensee Description of Commitment Change Audit Results -Verification of No.

Tracking No.

Licensee's Program for Managing Commitment Changes 4

83-142 KPS committed to a monthly (which was changed to Commitment is closed in the Comtrak system.

quarterly per the commitment change process) at-power containment inspection in reference 1, and took credit for This older commitment tracking system, Comtrak, the inspection in references 2, 3, 4, and 5. The decision did not provide a location to attach/describe an was made to rescind this at-power containment inspection, explanation for the changes; however, licensee due to various other containment inspections that occur provided an explanation in their letter dated May 29, cyclically, or as warranted by specific conditions. This 2010. Since the Comtrak system is not in use change has three key issues of concern. They are anymore and the new system, Central Reporting detection of containment flooding, detection of boric acid System, provides ample room for explanation, the corrosion, and detection of containment sump clogging.

added traceability enhances management of regulatory commitments.

Sample verifies that commitment changes are being managed successfully.

5 94-161 In a series of correspondence between KPS and the NRC, Commitment is closed in the Comtrak system.

it was determined that the minimum recirculation flow for the safety injection (SI) pumps at KPS was adequate.

This older commitment tracking system, Comtrak, However, KPS committed to performing disassembled did not provide a location to attach/describe an inspections of the Sl pumps every 15 years to ensure no explanation for the changes; however, licensee damage is occurring as a result of operation on mini-flow provided an explanation in their letter dated May 29, recirculation.

2010. Since the Comtrak system is not in use anymore and the new system, Central Reporting System, provides ample room for explanation, the added traceability enhances management of regulatory commitments..

Sample verifies that commitment changes are being managed successfully.

Item Licensee Description of Commitment Change Audit Results - Verification of No.

Tracking No.

Licensee's Program for Managing Commitment Changes 6

95-006 In a letter to the NRC dated January 30, 1995, Wisconsin Commitment is closed in the Comtrak system.

Public Service Corporation committed to implement the formal industry position on Severe Accident Management This older commitment tracking system, Comtrak, (SAM) at the Kewaunee Nuclear Power Plant.

did not provide a location to attach/describe an explanation for the changes; however, licensee provided an explanation in their letter dated May 29, 2010. Since the Comtrak system is not in use anymore and the new system, Central Reporting System, provides ample room for explanation, the added traceability enhances management of regulatory commitments.

Sample verifies that commitment changes are being managed successfully.

Note 1: The scope of this portion of the audit includes verifying that the licensee has established appropriate administrative controls for modifying or deleting regulatory commitments made to the NRC. The scope includes commitment changes reported to the NRC and commitment changes not reported to the NRC for the previous 3 years. See Audit Report Section 2.2 for further details.

Item NRC letter date No.

(Accession No.)

1 2/2/11 (ML102020662) 2 4/29/11 (ML111010523) 3 7/29/11 (ML11102A027) 4 8/31/11 (ML11192A249) 5 3/28/12 (ML120100040) 12 9/28/11 (ML11284A193)

TABLE 3 Review of Issued License Amendments and Relief Requests (See Note 1)

Description Safety Audit Results Evaluation Discusses Commitments?

(Yes/No)

Amendment 207, Conversion to the Yes The safety evaluation discusses 15 commitments that are Improved Technical Specifications relied upon; however, the safety evaluation states that the commitments were escalated into license conditions.

The staff used the commitments properly.

Amendment 208, Modification of the No service water supply to the No use of commitments component cooling heat exchangers.

Amendment 209, Use of new Yes The safety evaluation listed the 3 parts of the 1 licensee automatic load taps changers on commitment. The commitment(s) was not reviewed or new transformers.

discussed in the safety evaluation. In the conclusion, it was stated that commitments are said to "provide(s) assurance that adequate administrative procedures will be available."

No mention of acceptability or use in the conclusions was present, so the commitments were used properly by NRC staff.

Amendments 210, Cyber Security No The licensee provided 8 commitments, but the staff did not Plan mention the commitments in the safety evaluation, demonstrating that NRC staff did not rely on the commitments for the evaluation.

Amendment 211, Operation of No service water flow to component No use of commitments cooling heat exchangers Relief Request RR-G-5. Request for No relief from Section XI examination of No use of commitments welds Item NRC letter date Description Safety Audit Results No.

(Accession No.)

Evaluation Discusses Commitments?

(Yes/No) 13 5/3/12 Relief Request RR-2-4. Request for Yes ML12125A279 is a relief request dated May 3, 2012. The request (ML12125A279) a temporary deviation from the was reviewed and approved verbally to meet the licensee's requirements of ASME Section XI, schedule requirements. A Code-compliant repair was successfully Appendix IX, Article IX-1000, completed on May 6, 2012.

Paragraph (c)(2)

In the application, the licensee included the following commitments

[paraphrasing]:

After installation of leak limiting devices and prior to isolating the system in preparation for permanent repairs, VT-2 visual examinations will monitor leakage, if any, from devices.

Sealant injection pressure and volume will be controlled by work instructions and procedures to ensure no injection into the RHR system piping.

DEK will implement contingencies described in its letter I

until ASME Code repairs are completed [the contingency actions are drawn from abnormal operating procedures (AOPs) for which operators are trained and qualified.

The NRC staff reviewed the licensee's application and on May 5, 2012, verbally granted authorization for the requested relief. On October 4, 2012 (ML12271A366), the staff documented its May 5, 2012, decision regarding the request for relief by issuing its safety evaluation.

The October 4, 2012, SE was reviewed for this commitment audit.

NRC staff justified its decisions in the SE on the technical merits of the requested action. While the commitments were discussed in the SE, the NRC staff did not base their acceptance of the requested action on the licensee's commitments.

The staff used the commitments properly.

Item NRC letter date Description Safety Audit Results No.

(Accession No.)

Evaluation Discusses Commitments?

(Yes/No)

In the documented SE, NRC staff appears to have separately evaluated the technical merits of the requested action from the commitments made. Since the decision making on the relief request appears to be made separately from the review of the commitments, the NRC staff appears to have properly utilized the commitments. --

Note 1: The scope of this portion of the audit includes a review of all license amendments and relief requests issued during the previous 3 years for KPS. No exemptions were issued during the audit period. The intent of the review is to determine the extent to which commitments have been misapplied (e.g., commitment relied on by NRC staff rather than making the commitment an obligation or incorporating the commitment into a mandated licensing basis document). See Audit Report Section 2.3 for further details.

TABLE 4 Verification of Effective External Coordination for Managing NRC Commitment Changes Item Licensee Licensee No.

Licensee Submittal Tracking NRC Issuance Summary of Commitment Implementation Status Number Dominion Fleet procedure CM-AA-CRS-1 01 (Rev3)

The Dominion fleet latent debris sampling and contains the commitment.

The change is protected from evaluation procedure will be revised unintended modification by I

prior to the next refueling outage to require a crediting it to a KPS I

sampling frequency of every other refueling commitment in the Revision ML102730381 outage for low-fiber plants that are dependent Summary and on the affected (NRC-10-081) upon plant cleanliness to prevent formation of a procedural step. Dominion's 1

LC000454 None.

filtering bed of fiber on the recirculation strainer.

procedure format utilizes NRC Generic Letter 2004-02 The procedure will specify the sampling change bars for its revisions.

9/7/10 frequency may be relaxed after several Commitment is complete consecutive sample results (outages) that and under control by the identify minimal or no increasing volume of cooperating fleet document measured latent debris and ample latent debris control process.

inventory margin.

Implementation expected by the end of 2014. KPS staff is pursuing an expansion of a Letter of Agreement with neighboring licensee NextEra Energy Point Beach to provide ML13242A019 Mitigation strategies will be met with one piece mutual assistance. The existing (NRC-13-055) of equipment on site and a redundant piece of agreement addresses the mutual effect on the other party's 8/23/13 equipment available from another unaffected licensing basis and dependence 2

Request To Rescind Order LC001183 ML14059A411 1 fleet power station. This equipment will be on each other's calibration and Modifying Licenses For Beyond-stored in existing plant structures. Procedures maintenance activities.). The Design-Basis External Events will provide programmatic controls for the scope of the existing Letter of Agreement is adequate to (Order Number EA-12-049) strategies.

accomplish the commitment if its dependence on external efforts for availability is recognized.

Assistance from a neighboring plant would be closer than the nearest Dominion plant location.

In Progress 1 NRC rescinded this order on 6/10/14

ML14027A618 OFFICE LPL4-2/PM LPL4-2/PM NAME MOrenak CGratton DATE 3/5/214 12/16/214 Sincerely, IRA/

Michael D. Orenak, Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation RidsAcrsAcnw_MaiiCTR Resource RidsRgn3MaiiCenter Resource JWhited, NRR/DORL TOrf, NRR/DORL ROrlikowsky, RGN-111/DNMS/MCID/BC REdwards, RGN-111/DNMS/MCID/SRI LPL4-2/LA LPL4-2/BC LPL4-2/PM MHenderson DBroaddus (CGratton for)

MOrenak 12/18/14 12/23/14 12/23/14