ML050350272

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Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports for the Period 1/1/2003 Through 12/31/04
ML050350272
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 01/31/2005
From: Braun R
Exelon Nuclear
To:
Document Control Desk, NRC/FSME
References
SECY-00-0045
Download: ML050350272 (18)


Text

ExelonSM Exelon Nuclear Peach Bottom Atomic Power Station 1848 Lay Road Delta, PA 17314-9032 Telephone 717.456.7014 www.exeloncorp.com Nuclear 1OCFR 50.59,1 OCFR 72.48 January31, 2005 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station (PBAPS), Units 1, 2 and 3 PBAPS Independent Spent Fuel Storage Installation (ISFSI)Facility Operating License Nos. DPR-12, DPR-44 and DPR-56 NRC Docket Nos. 50-171. 50-277. 50-278. and 72-29 (ISFSI)

Subject:

Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports for the Period 1/1/2003 through 12/31/04 Enclosed are the 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports as required by 10CFR 50.59 (d)(2), 10CFR 72.48, and SECY-00-0045 (NEI 99-04). As required to be reported by Off-site Dose Calculation Manual Specification 3.9.2, there were no major changes to radioactive waste systems at PBAPS during the reporting period.There are no regulatory commitments contained in this transmittal.

If you have any questions or require additional information, please contact D. J. Foss at 717-456-4311.

Sincerely, Robert C. Braun Vice President Peach Bottom Atomic Power Station Attachments cc: S. J. Collins, Administrator, Region I, USNRC F. L. Bower, USNRC Senior Resident Inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania CCN 05-14005 6t7 2003-2004 Biennial 1OCFR 50.59, 10CFR 72.48 and Commitment Revision Reports Exelon Nuclear Peach Bottom Atomic Power Station Docket Nos. 50-171 50-277 50-278 72-29 2003-2004 BIENNIAL 10CFR 50.59, 10CFR 72.48 AND COMMITMENT REVISION REPORTS These reports are issued pursuant to reporting requirements for Peach Bottom Atomic Power Station Units 1, 2 and 3. These reports address tests and changes to the facility and procedures as they are described in the Peach Bottom Final Safety Analysis Report and Independent Fuel Storage Safety Analysis Report for the TN-68 Spent Fuel Cask. These reports consist of those tests and changes that were implemented between January 1, 2003 and December 31, 2004. Also, this report identifies commitments that were revised during the same time period and require reporting in accordance with the guidelines of NEI 99-04, Managing Regulatory Commitments Made By Power Reactor Licensees to the NRC Staff endorsed by SECY-00-0045.

1 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports PEACH BOTTOM ATOMIC POWER STATION UNIT 1, 2 AND 3 DOCKET NOS. 50-171, 50-277, 50-278, 72-29 BIENNIAL 1OCFR 50.59, 1OCFR 72.48 AND COMMITMENT REVISION REPORTS TABLE OF CONTENTS 10CFR 50.59 Report 3 10CFR 72.48 Report 9 Commitment Revision Report 10 2 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports EXELON NUCLEAR PEACH BOTTOM ATOMIC POWER STATION UNIT 1, 2 AND 3 DOCKET NOS. 50-171, 50-277, and 50-278 BIENNIAL 10CFR 50.59 REPORT JANUARY 1, 2003 THROUGH DECEMBER 31, 2004 EVALUATION SUMMARIES 3 2003-2004 Biennial 1OCFR 50.59, iOCFR 72.48 and Commitment Revision Reports Title: Temporary Removal of the Automatic Recirc Pump Trips and Generator Runback on Loss of Stator Water Coolant Units Affected:

2 & 3 Year Implemented:

2003 Brief

Description:

This activity involved the temporary removal of the automatic Recirculation Pump trips and Main Generator runback on loss of generator stator water cooling.Summary of Evaluation:

The 10CFR50.59 review addresses the temporary removal of the Unit 2 & 3 automatic main generator runback and trip of the recirculation pumps on a loss of stator water cooling. The pressure set point on the Unit 3 stator water coolant system is close to the operating pressure and has come close to affecting the operation of the plant. This happened during normal system manipulation with no actual system problems.

In order to minimize the risk of this scenario actually affecting Unit 3 or similar event from affecting Unit 2, the automatic recirculation pump trip and generator runback on a loss of stator cooling will be bypassed.

This temporary configuration is considered a compensatory action. The 1 OCFR50.59 review concludes that the proposed temporary change to remove the main generator stator water cooling recirculation pump trip and generator load runback will adversely affect an UFSAR described design function, trip of the recirculation pumps after loss of stator water cooling. It also concluded that this activity is not a test or experiment and does not involve a change to a methodology used to establish a design basis nor does it affect procedures as described in the UFSAR. The change does not require compensatory measures by the operators.

The event is bounded by other transient analysis for turbine trip and does not affect the equipment required for this analysis.

The reactor, generator, and turbine will not be operated beyond their design bases. A loss of stator water cooling after the proposed activity is bounded by the previously analyzed limiting event of a load reject without bypass valves. The probability and consequences of the bounding event were unchanged by the proposed activity since the original function may have resulted in a turbine trip as well. The activity does not affect any fission product barriers or evaluations used in establishing the design bases.Title: Technical Requirements Manual Section 3.5, Rev. 1 Recombiner Hydrogen Monitor Calibration Frequency Units Affected:

2 & 3 Year Implemented:

2003 Brief

Description:

This activity addressed a revision to the frequency of performing channel calibrations of the Recombiner Explosive Gas Monitor (Hydrogen Monitor).

This change revises the Technical Requirements Manual (TRM) Test Requirement (TR) 3.5.3 frequency from 31 days to 184 days Summary of Evaluation:

The 10CFR50.59 review concluded that the proposed change to the frequency of performing a channel calibration for the Hydrogen Monitors could potentially adversely affect the control of a UFSAR described design function; namely, the reliability of the equipment used to monitor the waste hold up system for 4 2003-2004 Biennial 1OCFR 50.59, 1OCFR 72.48 and Commitment Revision Reports hydrogen.

It also concluded that this activity is not a test or experiment and does not involve a change to a methodology used to establish a design basis nor does it affect procedures as described in the UFSAR.The activity was bounded by an analysis for a hydrogen detonation in the off-gas system and did not affect the equipment required for this analysis.

A potential degradation in the ability of the Hydrogen Monitors to detect a combustible limit in the off-gas system is bounded by the previously analyzed hydrogen detonation analysis.

The consequences of the bounding event were unchanged by the proposed activity since the original function may have resulted in a detonation as well. The probability of the failure in the off-gas system is no more than minimal since the off gas piping is designed to withstand detonations.

The activity does not affect any fission product barriers or evaluations used in establishing the design bases.Title: Recombiner Trip Logic Low Steam Flow Temporary Bypass (Revision 0 & Revision 1)Units Affected: Year Implemented:

3 2003 Brief

Description:

This activity addressed a temporary bypass of the Unit 3 recombiner trip on low steam flow to the system. Revision 0 of the 10CFR 50.59 Evaluation addressed the contacts being Jumpered out until the next refueling outage, 3R14 (September 2003). Revision 1 addressed extending the time period to the following refueling outage, 3R15 (September 2005). The steam flow indication to the Unit 3 Recombiner system had been trending down. All other system parameters indicate that the system was operating normally and that the actual steam flow had not been trending down. Increasing flow to compensate for the flow indication has produced the expected system response.

Troubleshooting has determined that there is a problem with the flow element or the instrument lines feeding the flow transmitters. -These components cannot be repaired without taking the recombiner out of service. The trips from this low flow signal need to be bypassed to prevent loss of the Recombiner because of the degraded flow signal.Summary of Evaluation:

The 10CFR50.59 review concluded that the proposed temporary change to the recombiner logic could adversely affect the control of a UFSAR described design function; namely, the ability to provide steam flow to dilute the hydrogen to a concentration below its combustible level. It also concluded that this activity is not a test or experiment and does not involve a change to a methodology used to establish a design basis nor does it affect procedures as described in the UFSAR. The activity is bounded by the determination that hydrogen detonation in the off-gas system is not a concern as originally stated in the UFSAR and there are other methods for determining adequate dilution flow. A potential degradation in the dilution flow is still bounded by the previously analyzed hydrogen detonation analysis.

The consequences of the bounding event were unchanged by the proposed activity since the original function may have resulted in a detonation as well. The probability of the failure in the off-gas system is no more than minimal since the off gas piping is designed to withstand detonations.

The activity does not affect any fission product barriers or evaluations used in establishing the design bases.Title: Permanent Removal of the Automatic Recirc Pump Trips and Generator Runback on Loss of Stator Water Coolant 5 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports Units Affected: Year Implemented:

2&3 2003 Brief

Description:

This activity involved the permanent removal of the automatic Recirculation Pump trips and Main Generator runback on loss of generator stator water cooling. It also adds a new main control room alarm "GEN. PROTECTION CIRCUIT ENERGIZED".

The purpose of this alarm is to positively identify to the operators that a turbine trip will be generated in either 2 or 3.5 minutes, depending on generator load. Operator action will be a GP-4 reactor shutdown.

The pressure setpoint on the stator water coolant system is close to the operating pressure and has come close to affecting the operation of the plant. This happened during normal system manipulation with no actual system problems.

In order to minimize the risk of this scenario (that actually affected Unit 3), the automatic Recirc M/G set trip and generator runback on a loss of stator cooling will be removed.Summary of Evaluation:

The 50.59 concluded that nuclear safety is not negatively impacted and that this modification remains enveloped by the turbine trip (electrical load loss) without bypass valves event. The 10CFR50.59 review also concluded that the proposed change to remove the main generator stator water cooling Recirculation MUG set trip and generator load runback will adversely affect an UFSAR described design function.

A loss of stator water cooling after the proposed activity is bounded by the previously analyzed limiting event of a load reject without bypass valves. The probability and consequences of the bounding event were unchanged by the proposed activity since the original function may have resulted in a turbine trip as well.The activity does not affect any fission product barriers or evaluations used in establishing the design bases. The 10CFR50.59 review concludes that the proposed change to remove the main generator stator water cooling recirculation pump trip and generator load runback will adversely affect an UFSAR described design function, trip of the recirculation pumps after loss of stator water cooling. It also concluded that this activity is not a test or experiment and does not involve a change to a methodology used to establish a design basis nor does it affect procedures as described in the UFSAR. The change does not require compensatory measures by the operators.

The event is bounded by other transient analysis for turbine trip and does not affect the equipment required for this analysis.

The reactor, generator, and turbine will not be operated beyond their design bases. A loss of stator water cooling after the proposed activity is bounded by the previously analyzed limiting event of a load reject without bypass valves. The probability and consequences of the bounding event were unchanged by the proposed activity since the original function may have resulted in a turbine trip as well. The activity does not affect any fission product barriers or evaluations used in establishing the design bases.Title: Control Rod Over Travel Alarm 50.59 Evaluation Units Affected: Year Implemented:

2 2003 Brief

Description:

This activity will temporarily remove the erroneous over travel alarm for the 18-11 control rod on Unit 2. Although this 50.59 Evaluation is written for Control Rod 18-11, which has an over travel logic circuit short, this Evaluation is applicable to other Control Rods in which troubleshooting has identified a short in the over travel logic circuit.6 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports Summary of Evaluation:

The Unit 2 alarm for control rod overtravel has been annunciating with no rods being moved.Troubleshooting has found that rod 18-11 has been causing this problem and that an intermittent ground exists on the wire for the overtravel reed switch contact. The control room alarm for this function is a common alarm for all 185 control rods. When this alarm comes in for a single rod it masks any other control rod overtravel alarm. The control rod over travel alarm function provides operations with an indication that the control blade may have become disconnected from the drive. The primary purpose of this indication is to alert the operators of the decoupled condition, which is a precursor to a control rod drop accident.

The effect of this activity is to defeat the control room rod over travel annunciator for rod 18-11 and to ensure the control room annunciator for rod over travel is functional for the other 184 control rods. Alternate methods still exist for ensuring that control rod 18-11 is still coupled. The change was determined to not have more than a minimal increase in the probability of occurrence of an accident or equipment malfunction.

There is also no effect on the consequences of an accident or the possibility of a different accident.

The change does not affect any technical evaluations or fission product barriers.Technical Specification SR 3.1.3.5 can be performed since two additional methods of identifying a rod over travel condition (loss of 48 position on the full core display and rod drift alarm) can be used for rod 18-11 when its rod over travel alarm is defeated.Title: Technical Requirements Manual (TRM) -Revision to Remove Plant Shutdown Statements and Update TR 3.0.3 Requirements Units Affected:

2 & 3 Year Implemented:

2003 Brief

Description:

This activity involves an upgrade to the PBAPS TRM to remove shutdown statements and revise the TR 3.0.3 actions for missed test requirements.

Summary of Evaluation:

The changes are made to prevent unnecessary plant shutdowns.

Accident analysis credited and risk significant systems are included in the Tech Specs in accordance with 1OCFR 50.36. TRMS sections ensure that appropriate actions are taken with regards to nuclear safety. These changes could potentially avoid an unnecessary plant shutdown.

These changes do not necessarily prevent all plant shutdowns.

They provide the benefit of evaluating each particular situation and making an informed decision based on the conditions.

These changes were screened In as being a change to the Updated Final Safety Analysis Report in that there are changes in the controlling of design functions.

The 10CFR 50.59 evaluation determined that there were no impacts to the probability or consequences of accidents or malfunctions of equipment important to safety. Also, there were no accidents of a different type or malfunctions of equipment with a different result involved.

The design basis limits for a fission product barrier was not exceeded or altered. There was no departure from a method of evaluation described in the UFSAR. TR 3.0.3 and the associated bases are revised to allow for missed Tests to be performed up to the greater of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the Test frequency.

This change prevents unnecessary actions to be taken in the event of a missed Test. Declaring equipment inoperable has been determined to be overly conservative based on probabilistic and other empirical industry data. This change was screened in since there involves a change to section TR 3.0.3 which could potentially involve an adverse affect. Therefore, a 10CFR 50.59 evaluation was required for these changes. The 10CFR 50.59 evaluation determined that there were no impacts to the probability or consequences of accidents or malfunctions of equipment important to safety.Also, there were no accidents of a different type or malfunctions of equipment with a different result 7 2003-2004 Biennial 10CFR 50.59, 1OCFR 72.48 and Commitment Revision Reports involved.

The design basis limits for a fission product barrier was not exceeded or altered. There was no departure from a method of evaluation described in the UFSAR.Title: Drywell Equipment Drain Sump Temporary Logic Reconfiguration Units Affected:

2 Year Implemented:

2004 Brief

Description:

This activity temporarily altered the logic for the Unit 2 Drywell equipment drain pumps. Instead of having an alternating scheme for the pumps, one pump will perform all the pump outs on the high-high set point. The alarm will have a time delay added to prevent an alarm each time the pump operates.

The alarm will come in if the pump cannot adequately reduce sump level.Summary of Evaluation:

It was determined that temporarily reconfiguring the U/2 drywell sump pump logic involved a change to a SSC that adversely affects a UFSAR described design function.

The pump logic is an UFSAR described design function in section 4.10 where the alternating pump start logic is described.

The 50.59 Evaluation determined that this temporary change 1) does not increase the frequency or consequences of a previously evaluated accident or create the possibility of a new accident since no accident initiators are involved;

2) does not increase the likelihood of occurrence of a previously evaluated malfunction of an SSC important to safety because the affected equipment does not interface with any previously evaluated;
3) does not increase the consequences of a previously evaluated malfunction of an SSC important to safety because there are no consequences associated with the drywell sump pumps; 4) does not create the possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the UFSAR because no new failure modes are introduced;
5) does not result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered because no system parameters will change as a result of this ECR.There were no 10CFR 50.59 Evaluation Reports performed

/ implemented for Unit 1 during this reporting period.End of 10CFR 50.59 Report 8 2003-2004 Biennial 10CFR 50.59, 1OCFR 72.48 and Commitment Revision Reports EXELON NUCLEAR PEACH BOTTOM ATOMIC POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NO. 72-29 BIENNIAL 10CFR 72.48 REPORT JANUARY 1, 2003 THROUGH DECEMBER 31, 2004 10CFR 72.48 EVALUATION SUMMARIES There were no 1 OCFR 72.48 Evaluations performed

/ implemented during this reporting period.End of 10CFR 72.48 Report 9 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Repbrts EXELON NUCLEAR PEACH BOTTOM ATOMIC POWER STATION UNIT 1, 2 AND 3 DOCKET NOS. 50-171, 50-277, and 50-278 BIENNUAL COMMITMENT REVISION REPORT JANUARY 1, 2003 THROUGH DECEMBER 31, 2004 10 2003-2004 Biennial 10CFR 50.59, 1OCFR 72.48 and Commitment Revision Reports Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 10/30/91, Response to Inspection 98-28-01 TO1 677 Evaluate criteria for performing Radiation Protection pre-job reviews Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radiation Protection have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 6/23/82, Response to Inspection 82-05/05 T03337 Use of redundant meters for Radioactive Waste Surveys Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radiation Protection have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter from NRC, 5/13/81, NRC Acknowledgement of Violation 80-18/10 T03088 Periodically calibrate neutron survey meters Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radiation Protection have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 4/27/83, Response to Inspection 82-19/18 T03147 Placement of signs on refuel floor to inform personnel to ensure health physics personnel availability 11 2003-2004 Biennial lOCFR 50.59, 10CFR 72.48 and Commitment Revision Reports Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radiation Protection have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 7/25/94, Response to Inspection 94-06/06 T03341 Implement administrative procedure on configuration control of digital based plant process equipment Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within configuration control have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 117/86, Response to Inspection 85-42/42 T03335 Revise procedures for proper orientation of slings used for shipping casks Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radioactive waste management have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Letter to NRC, 8/28/85, Response to Inspection 85-27/25 T03332 & T00327 12 2003-2004 Biennial 1OCFR 50.59, IOCFR 72.48 and Commitment Revision Reports Nature of Commitment:

Revise procedures for proper orientation of drum ring bolts when loading multiple radioactive waste drums Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radioactive waste management have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 12/31/86, Response to Inspection 86-21/22 T03330 Revise procedures to require independent review of documents used to classify radioactive waste shipments Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radioactive waste management have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 4/27/83, Response to Inspection 82-19/1 8 T03147 Placement of signs on refuel floor to inform personnel to ensure health physics personnel availability Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radioactive waste management have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Letter to NRC, 6/18/81, Response to Inspection 80-36/29 T03325 & T00307 13 2003-2004 Biennial 1OCFR 50.59, 1OCFR 72.48 and Commitment Revision Reports Nature of Commitment:

Revise procedures for proper orientation of drum ring bolts when loading multiple radioactive waste drums. Ensure supervisory in progress inspections and signoffs.Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radioactive waste management have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 2/3/89, Response to Inspection 85-31/28 T00305 Coordinators will verify liner serial numbers on shipping papers and sign off on radioactive waste shipment Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radioactive waste management have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 12/7/81, Response to Inspection 81-10/11 T03067 Revise procedures and training to upgrade standards in using respirators and breathing air equipment Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within radiation protection management have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 1/23/97, Response to Inspection 96-06/06 T00305 Upgrade procedures and training for safety related modifications Summary of Justification:

14 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within configuration control processes have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 4/27/83, Response to Enforcement Action 83-7 T03019 Upgrade startup procedures to ensure that non-automatic containment isolation procedures are in the proper position.Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within equipment control processes have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letters to NRC (7/3/90, 10/16/90, 4/30/91, 3/5/93), Response to NRC Bulletin 90-01 & Licensee Event Report (LER) 2-90-021 T00042 & T00892 Increase monitoring of Reactor water level instrumentation and establish an enhanced Rosemount 1153 Transmitter Fill-Oil Loss Monitoring Program.Summary of Justification:

The build-up of non-condensable gases in this instrumentation has been eliminated due to the installation of a modification.

Also, normal daily round include criteria to identify level indication problems.

The transmitters have reached their monitoring time thresholds and may be excluded from the need for monitoring for loss of fill oil. Letter dated 3/15/93 allows for exclusion from the monitoring program once the instruments meet their monitoring time thresholds.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 12/30/83, NRC Inspection of NUREG-0737 Items T031 68 Establish requirements for activating the Unit 1 laboratory equipment as alternate for post-accident sampling capability 15 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports Summary of Justification:

The commitment was for an alternate chemistry laboratory for monitoring of samples related to post-accident sampling capability.

This was originally satisfied by using the Unit 1 laboratory facility.

This has been changed to use an off-site laboratory facility.

An evaluation has determined that samples may be shipped to alternate nearby Exelon facilities in a timely manner.Letter Source: Exelon Tracking No.: Nature of Commitment:

NRC Inspection Report 83-34/32, Closure of Violation 80-03-03 T03166 Require off gas radiation monitors to be placed in service prior to plant start-up Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

Improved standards and practices within start-up procedures addressed this issue and are controlled within Exelon standard documents.

There is no longer a need to track this commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

Letter to NRC, 1/29/90 Concerning NRC Generic Letter 89-13 Implementation T041 97 Perform sounding operations of intake canal once per year Summary of Justification:

The initial frequency of once per year was based on engineering evaluations of silt level in the intake canals. Based on routine monitoring for silt and the results of dredging of the intake canals, it has been determined that a frequency of every 1490 days is sufficient to ensure appropriate intake canal silt conditions.

Letter Source: Exelon Tracking No.: Nature of Commitment:

NRC Inspection Report 86-11/11, 6/9/86 T03416 Provide a more specific way of documenting recommendations in audit reports 16 2003-2004 Biennial 10CFR 50.59, 10CFR 72.48 and Commitment Revision Reports Summary of Justification:

This is a historical commitment.

The corrective actions taken were effective and the station is in compliance with NRC requirements.

The current NRC approved Quality Assurance Topical Report requires that recommendations are made when appropriate.

Improved standards and practices within the Nuclear Oversight area have addressed this issue and are proceduralized within the Exelon standard documents.

There is no longer a need to track this commitment.

End of Commitment Revision Report 17