BYRON 2010-0017, Regulatory Commitment Change Summary Report

Regulatory Commitment Change Summary Report

ML100610085
Person / Time
Site:	Byron
Issue date:	03/01/2010
From:	Enright D Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1.10.0101, BYRON 2010-0017
Download: ML100610085 (8)

Text

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'vvvvw,c~x('ion(()r p.COn"i Nuclear 44S0 North Cerrndn Crun.hRoJd Byron, 'L 61010-9794 March 1, 2010 LTR; BYRON 2010-0017 File: 1.10.0101 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

2009 Regulatory Commitment Change Summary Report Enclosed please find the "Regulatory Commitment Change Summary Report" for Byron Station.

This report contains summary information from January 1, 2009 through December 31, 2009.

Revisions to docketed regulatory commits were processed using the current revision of Nuclear Energy Institutes' document NEI 99-04, "Guidelines for Managing Nuclear Regulatory Commission (NRC) Commitment Changes."

If you have any questions concerning this report, please contact David Gudger, Regulatory Assurance Manager at (815) 406-2800.

Respectfully, Daniel J. Enright Site Vice President Byron Station DJE ffLHI cy Enclosure

ATTACHMENT BYRON STATION REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT FOR 2009 Original Document and Commitment:

Commitment AR 10651 - Response to NRC Generic Letter 89-13 letter to US NRC from M. H.

Richter, Commonwealth Edison Co., dated January 29, 1990. Quarterly scheduled Essential Service Water (SX) make-up pump performance test will identify significant fouling of piping between the river screen house and the SX cooling towers. Fouling will be detected by trending the throttle position of the pumps discharge valve required to achieve proper pump differential pressure and flow rate.

Subject of Change:

Change made: Currently the SX make-up pumps discharge valves are operated at locked full open. An evaluation of potential fouling is completed by trending pump differential pressure and flow rate.

The change is needed to indicate the station is trending for fouling based off of the flow rate and differential pressure, not by throttling the OSX029A1B valves. The Generic Letter 89-13 requirements continue to be satisfied.

Status:

The commitment was changed under Commitment Change Number 09-008.

LS-AA-110 Revision 6 Page 14 of 29 ATTACHMENT 1 Commitment Change Evaluation Form Part 1: Commitment Change Description Page 1 of 7 Commitment Change Tracking # CJ9 -tJE:3 (Provided by Licensing/Regulatory Assurance as applicable)

CT Number: ~L /39 -0 Commitment Source Document: ~B...JQ\#61 J]CMT trcorcL9.D-l81QO k:. .-::r Requestor: Tony Ziegelbauer Dept: PEO Date: >J.!.!-I.!!1.. Phone: 2090 Functional Area Manager Approval: l utt 1t7l1!,~61 KrJ;/llnn l~ate: 51J1.Jo't Phone: 0fR I LicenslngiRegulatory Assurance ,auor.1Jw. ! <... r. IY r r:, -, Dolo: "I!-J!L Ph0110:  ? V'J Commitment Tracking Coordinator. ~rt1ul11 ,Ill lO 1'..1111-- u Date: -iJJl,09 2f2..() I

. Phone:

Orioinal Commitment

Description:

See Attachment 2 Revised Commitment

Description:

See Attachment 2 JustificatiQfl for Change The;~tS needed to indicate the station is trending for fouling based off of the flow rate and differential I press ,ot by throttling the OSX029A1B.

Is there a potential adverse reoulatorv impact? Explain No, the station has been and will continue to meet the intent of Commitment Letter 90-08400 by trending for fouling in the SX make-up lines.

I Summarize and attach part 2 (i.e. what is the appropriate change process?)

The commitment may be changed. Obtain management approval on Part 1.

SRS 5A.106 or 5A.107 I Notify NRC in next annual Commitment Change Summary Report or UFSAR Update? .L YES NO

LS-AA-110 Revision 6 Page 15 of 29 ATTACHMENT 1 Commitment Change Evaluation Form Part 2: Determination of Appropriate Change Process Page 2 of 7 NOTE: The following questions correlate to the Figures 1 and 2 decision process flowcharts.

1. Is the existing commitment located in the Updated Final Safety Analysis Report, Emergency Plan, Quality Assurance Plan, Fire Protection Program, Security Plan, or Decommissioning Plan (Le. 10 CFR 50.54(a), 10CFR50.54(p), 10CFR50.54(q),

10CFR50.82(a), 10CFR72.48, 10CFR50.71(e))?

NOTE: Certain types of commitments described in the UFSAR do not require evaluation under a codified process, (e.g., 10 CFR 50.59), and therefore should be evaluated within the commitment management program. (Reference Decision 1 of Attachment 2.)

~ Continue with Question 2.

Yes. STOP. Refer to and use the codified process as appropriate to evaluate commitment. This form may be discarded.

2. Could the change negatively impact the ability of a structure, system, or component to perform its safety function or negatively impact the ability of personnel to ensure the structure, system or component is capable of performing its intended safety function?

(Reference Fig. 2 of Attachment 2.)

~ Briefly describe the rationale and continue with Question 3.

This change does not impact how the system is operated.

Yes. Perform an evaluation using 10 CFR 50.92 criteria. Does a significant hazard consideration exist?

LS*AA*110 Revision 6 Page 16 of 29 ATTACHMENT 1 Commitment Change Evaluation Form Part 2: Determination of Appropriate Change Process Page 30f7 Yes. STOP. DO NOT MAKE THE CHANGE. Work through Licensing/Regulatory Assurance to obtain prior NRC approval prior to making the change. This form may be discarded.

No. Attach a copy of the evaluation and continue with Question 3.

NOTE: If the original commitment was made in response to a NRC Notice of Violation and has been implemented for less than two years, then supplement the NRC Notice of Violation response identifying that the commitment is being changed or deleted, as applicable. This supplement to the violation should be submitted to the NRC prior to making the commitment change. .

3. Was the original commitment (e.g., response to NOV, NCV etc.) necessary for compliance with an obligation (Le., rule, regulation, Order, or license. condition?

No. Continue with Question 4.

~. Does the changed commitment preserve compliance?

No. EXIT PROCESS. DO NOT MAKE THE CHANGE.

Work with Licensing/Regulatory Assurance to obtain prior NRC approval before making the change. This form may be discarded.

~ Briefly describe the rationale and proceed to Question 6.

The station has been and will continue to meet the intent of Commitment Letter 90-08400 by trending for fouling in the SX make-up lines.

4. Was the original commitment:

a. Explicitly credited as the basis for a safety decision in an NRC SER,

LS*AA*110 Revision 6 Page 17 of 29 ATTACHMENT 1 Commitment Change Evaluation Form Part 2: Determination of Appropriate Change Process Page 4 of 7 OR

b. Made in response to an NRC Bulletin or Generic Letter, OR

c. Made in response to a request for information under 10 CFR 50.54(f),

10 CFR 2.204, or a Confirmatory Action Letter.

OR

d. Identified as a corrective action in response to a NRC Notice of Violation?

rI (~+\e No. Continue with Question 5.

Go to Question 6.

5. Was the original commitment made to minimize recurrence of an adverse condition (Le.,

a promise to take a corrective action by a given date stated in an LER)?

@ STOP. The commitment may be changed without NRC notification. Obtain management approval on Part 1, and submit to Licensing/Regulatory Assurance.

Yes. Is the changed commitment necessary to minimize recurrence of the adverse condition?

No. STOP. The commitment may be changed without NRC notification.

Document rationale, obtain management approval on Part 1, and submit to Licensing/Regulatory Assurance.

Yes. STOP. The commitment may be changed. Obtain management approval on Part 1, and submit to Regulatory Assurance/

Licensing for notification to the NRC in the next annual Commitment Change Summary Report or UFSAR Update.

I I

LS-AA*110 Revision 6 Page 18 of 29 ATTACHMENT 1 Commitment Change Evaluation Form Part 2: Determination of Appropriate Change Process Page 50f7

6. Has the original commitment been implemented?

No. EXIT PROCESS. Work with Licensing/Regulatory Assurance to provide notification of the changed commitment to the NRC. This will be accomplished by submitting a supplement of the original document.

Notification to the NRC of the intent to change a commitment should be made as soon as practicable after the change is approved by licensee management but before any committed completion date. Timely notification should normally be made within 30 days or before the committed completed date whichever is sooner. This form may be discarded.

STOP. The commitment may be changed. Obtain management approval on Part 1, and submit to Licensing/Regulatory Assurance for notification of the NRC in the next annual Commitment Change Summary Report or UFSAR Update.

Attachment 2 Original Commitment

Description:

Genelic Letter 89-13 item I requires: Implementation and Maintenance of an ongoing program of Surveillance and Control Techniques to significantly reduce the incidence of flow blockage problems as a result of bio-fouling. In response to this requirement, Byron Station, via Corporate Response of Reference 2 committed to a Surveillance Technique "A", which states in part" ... Quarterly scheduled SX make-up pump performance test will identify significant fouling of piping between the RSH and the SX cooling Tower."

To enhance OBVS O.5-3.SX.l-l, a step will be added to record the pump discharge valve throttle position required to achieve proper pump differential pressure and flow rate.

Revised Commitment

Description:

Generic Letter 89-13 item I requires: Implementation and Maintenance of an ongoing program of Surveillance and Control Techniques to significantly reduce the incidence of flow blockage problems as a result of bio-fouling. In response to this requirement, Byron Station, via Corporate Response of Reference 2 committed to a Surveillance Technique "A", which states in part " ... Quarterly scheduled SX make-up pump performance test will identify significant fouling of piping between the RSH and the SX cooling Tower~"

Currently the OSX029NB are operated at locked full open and is documented in procedures, OBVSR 5.5.8.SX.5-1I2AfB and OBOSR 5.5.8.SX.5-1I2C and an evaluation of a potential degraded condition is completed by trending pump differential pressure and flow rate for fouling or pump degradation.