ML090330076
ML090330076 | |
Person / Time | |
---|---|
Site: | Peach Bottom |
Issue date: | 01/28/2009 |
From: | Maguire W Exelon Generation Co, Exelon Nuclear |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
Download: ML090330076 (17) | |
Text
Exelon Nuclear www.exeloncorp.com Exekrn.
Peach Bottom Atomic Power Station Nuclear 1848 Lay Road Delta, PA 17314-9032 10CFR 50.59, 10CFR 72.48 January 28, 2009 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station (PBAPS), Units 1, 2 and 3 and 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 1/1/2007 through 12/31/08 Enclosed are the 2007-2008 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, William F.
Site Vice President Peach Bottom Atomic Power Station cc: Fred Bower, Senior Resident Inspector, USNRC, PBAPS R. R. Janati, Commonwealth of Pennsylvania Document Control Desk, USNRC, Washington DC CCN: 08-110 Attachments kA A-550O
2007-2008 Biennial 10CFR 50.59 and IOCFR 72.48 Reports Exelon Nuclear Peach Bottom Atomic Power Station Docket Nos. 50-171 50-277 50-278 72-29 2007-2008 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, 2007 and December 31, 2008. 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
2007-2008 Biennial 10CFR 50.59 and 10CFR 72.48 Reports PEACH BOTTOM ATOMIC POWER STATION UNIT 1, 2 AND 3 DOCKET NOS. 50-171, 50-277, 50-278, 72-29 BIENNIAL 10CFR 50.59, 10CFR 72.48 AND COMMITMENT REVISION REPORTS TABLE OF CONTENTS 10CFR 50.59 Report 3 10CFR 72.48 Report 10 Commitment Revision Report 11 2
2007-2008 Biennial 10CFR 50.59 and I0CFR 72.48 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, 2007 THROUGH DECEMBER 31, 2008 EVALUATION SUMMARIES 3
2007-2008 Biennial 10CFR 50.59 and 10CFR 72.48 Reports
Title:
Technical Specification Bases Change to Incorporate Technical Specification Task Force (TSTF) 476 involving an Improved Banked Position Withdrawal System (BPWS) Control Rod Insertion Process Units Affected: 2 and 3 Year Implemented: 2007 Brief
Description:
This activity involves a change to the Technical Specification (TS) Bases for Units 2 and 3. The change incorporates the option to use an Improved BPWS Control Rod Insertion Process during plant shutdown maneuvers. The proposed process allows control rods to be inserted directly to position 00 without stopping at intermediate notch positions, provided that all withdrawn control rods have been confirmed to be coupled to their respective drives prior to operation below the Low Power Set-point (LPSP). The BWR Owners Group (BWROG) sponsored the Improved BPWS Control Rod Insertion Process via TSTF-476, Revision 1.
GE Nuclear Energy (GENE) evaluated the Improved BWR Control Rod Insertion Process in Licensing Topical Report NEDO-33091, "Improved BPWS Control Rod Insertion Process". NEDO-33091 Revision 2 has been reviewed and generically accepted by the NRC, as documented in a June 16, 2004 Safety Evaluation Report.
Summary of Evaluation:
Modifying the Unit 2 and 3 Tech Spec Bases to allow the use of the Improved BPWS Control Rod Insertion Process supports the performance of "soft" plant shutdowns by allowing insertion of control rods to the full-in position in a single step (under limited plant shutdown scenarios), eliminating existing BPWS requirements to bank rods at intermediate notch positions. This change has no adverse impact on the design basis or nuclear safety. The Improved BPWS Control Rod Insertion Process eliminates the possibility of a Control Rod Drop Accident (CRDA) by requiring that all withdrawn rods are verified to be coupled to their respective drive mechanisms prior to operating below the Low Power Set-point (LPSP) during plant shutdowns. For all other power maneuvers below the LPSP, the original BPWS guidance will continue to govern. Implementation of the Improved BPWS Control Rod Insertion Process will have no impact on the functionality, performance or reliability of plant equipment. The Improved BPWS Control Rod Insertion Process will result in an overall reduction in discrete reactivity manipulations and less wear on the Reactor Manual Control and Control Rod Drive systems.
The proposed activity does not pose any adverse effects on plant systems, structures, or components (SSCs). This changes does not adversely affect how SSCs are operated or controlled. The Improved BPWS Control Rod Insertion Process will meet all CRDA design criteria by eliminating the possibility of a CRDA under predefined plant shutdown scenarios. This is accomplished by ensuring that all withdrawn control rods are coupled to their Drive mechanisms prior to lowering power below the LPSP. The NRC has generically approved the Improved BPWS Control Rod Insertion Process, as described in NEDO-33091.
Peach Bottom Units 2 and 3 meet all applicable requirements necessary to implement this change, as specified in NEDO-33091. The 10CFR 50.59 Evaluation concluded that the proposed change does not constitute a departure from a method of evaluation described in the UFSAR used in establishing the design bases or in the safety analyses. This conclusion is based on the inherent conservatism of the Improved BPWS Control Rod Insertion Process relative to the existing BPWS methodology (possibility of CRDA is eliminated), coupled with the fact that NRC has reviewed and generically approved the Improved BPWS Control Rod Insertion Process methodology (Licensing Topical Report NEDO-33091) for application to the BWR-4 reactor design.
4
2007-2008 Biennial 10CFR 50.59 and 10CFR 72.48 Reports
Title:
Alternate Seismic Evaluation Method to Qualify New and Replacement Equipment for Certain Applications, Revision 1 Units Affected: 2 &3 Year Implemented: 2007 Brief
Description:
This change allows for an alternate means to qualify new and replacement equipment for use at PBAPS, in those plant locations where the Seismic Qualification Utilities Group (SQUG) criteria were applied during resolution of NRC Unresolved Safety Issue (USI) A-46.
Revision 1 of the 50.59 Evaluation was prepared to address an NRC comment resulting from an NRC inspection. The NRC noted that, although the summary of the 50.59 Evaluation explained the basis for the use of revision 3A of the SQUG Generic Implementation Procedure (GIP), the 50.59 Evaluation itself does not address this issue. Therefore, a paragraph is added to the Evaluation in revision 1 to explain the basis for use of GIP-3A.
Summary of Evaluation:
The Seismic Qualification Utilities Group (SQUG) has developed a standardized method for seismic qualification of equipment. This method was originally developed as a means for older plants to evaluate equipment to satisfy USI A-46, and has since been endorsed by the NRC as an acceptable method for use beyond USI A-46, on a continuing basis, as allowed by each site's specific license commitments.
This activity allows for the use of Revision 3A of the SQUG Generic Implementation Procedure (GIP-3A) for the seismic design and verification of modified, new, and replacement equipment as an alternative to the methods currently specified in the UFSAR for the seismic design of Seismic Category I equipment.
This provides an alternate means to qualify new and replacement equipment for use at PBAPS, in those plant locations where the SQUG criteria were applied during resolution of USI A-46. Previously acceptable methods for meeting the UFSAR seismic design criteria will still be considered acceptable and remain part of the plant's licensing basis. Typically, the elements of these different methods would not be mixed or combined for evaluating the seismic adequacy for any single item of equipment unless a specific analysis justifies such an approach. No physical changes to the plant are being made by this activity. The new methodology for seismic qualification of equipment has been accepted by the industry and the NRC, and it provides a conservative approach to ensure that equipment will perform under seismic loading conditions, based on past experience data and test data. The UFSAR states that empirical methods, consisting of testing and experience, are used for the design of complex equipment for which simple stress analysis can be impractical. The SQUG methodology utilizes testing and experience data, applied under a strict and conservative set of rules, to demonstrate the seismic adequacy of equipment in bounded applications. The NRC has reviewed the SQUG methodology in GIP-2, and has generically approved it for use beyond the resolution of USI A-46, pending review of site-specific licensing requirements. In particular, the NRC Safety Evaluation Report issued to Peach Bottom regarding the resolution of USI A-46, Supplement No. 1 to Generic Letter 87-02, states that the licensee may revise its licensing basis to incorporate GIP-2, in accordance with 10CFR50.59 and 10CFR50.90 as required.
5
2007-2008 Biennial 10CFR 50.59 and IOCFR 72.48 Reports
Title:
Plant Shutdown Procedure Revision to Defeat the Scram Function when the Plant Mode Switch is in the SHUTDOWN Position Units Affected: 2&3 Year Implemented: 2007 Brief
Description:
This activity supports the Temporary Configuration Change via revision of procedure, GP-3 "Normal Plant Shutdown". Two jumpers (per Unit) will be installed to bypass the Mode Switch to SHUTDOWN Scram contacts. No other RPS or mode switch functions are affected. A 50.59 Evaluation was performed for the subject revision to procedure GP-3 because the jumper installation eliminates the Main Control Room Mode Switch in SHUTDOWN Scram capability. Although ensuring all rods have been inserted is a prerequisite in the section of GP-3 that installs the jumpers, the UFSAR explicitly states that a Scram is initiated whenever the mode switch is placed in the SHUTDOWN position. Installing the jumpers eliminates this function and is considered an adverse change to a UFSAR described design function. The manual Scram functions from the Main Control Room Manual Scram pushbuttons and from the RPS test switches are unaffected by the installation of the jumpers.
Summary of Evaluation:
To support the Soft Shutdown initiative, bypassing the Reactor Mode Switch to Shutdown Scram function is required to prevent Scramming the control rods from position 00 with fully charged Control Rod Drive (CRD) accumulators. Scrams from position 00 should be limited to ensure impacts to CRD component lifetime and system reliability are minimized. Scrams with rods at position 00 can result in degradation to drive seals. Additionally, reducing the frequency of manual scrams during plant shutdowns helps minimize the discharge of loose "crud" from the fuel and reactor internals, resulting in lower plant dose rates.
The only function the jumpers will impact is the Scram provided when the mode switch is taken to SHUTDOWN. All 185 control rods will already be fully inserted prior to installing the jumpers. Valve repositioning for Scram pilot valves, for backup Scram valves, and for Scram discharge volume vents and drains is not required when the mode switch is placed in shutdown since all rods will already be inserted.
All other functions of the mode switch will occur when the mode switch is taken to shutdown. This activity is intended to enhance the reliability of the control rod drive system by eliminating unnecessary hydraulic actuations when a soft shutdown is performed and helping to minimize the discharge of loose "crud" from the fuel and reactor internals, resulting in lower plant dose rates. The intentional act of defeating the Technical Specification RPS function of the mode switch does not compromise plant safety and is not being made for operational convenience. Plant safety is not compromised since all control rods will be verified as fully inserted prior to defeating the mode switch to SHUTDOWN RPS function. The jumpers are in place for a very short period of time. This activity is not a compromise of plant safety since the aggregate effect of performing a 'soft shutdown' is to enhance nuclear and radiological safety.
Installing the jumpers disables this UFSAR described design function and is considered an adverse change to a UFSAR described design function. Temporarily bypassing the Mode Switch to SHUTDOWN Scram signal by installing jumpers to keep the associated Reactor Protection System (RPS) trip channels energized is acceptable because all 185 control rods will be verified to be fully inserted prior to installing the jumpers. The 50.59 evaluation has concluded that the plant responses to design basis accidents and transients are maintained as described in the UFSAR. This activity does not impact any accident or abnormal operating transient initiators; therefore, it does not result in the possibility for an accident of a different type than any previously evaluated in the UFSAR. The activity does not create a possibility for a 6
2007-2008 Biennial 10CFR 50.59 and IOCFR 72.48 Reports malfunction of an SSC important to safety with a different result than any previously evaluated in the UFSAR as all jumper failure possibilities have been analyzed and the consequences are bounded.
Title:
Procedure Revision for Continuous Venting of Recirculation Seals Units Affected: 2 &3 Year Implemented: 2007 Brief
Description:
This 10CFR50.59 evaluation addresses the use of procedure AO 2A.16-2(3),
Manual Adjustment of Recirculation Pump Seal Second Stage Pressure, for the continuous venting of the second stage recirculation pump seal for the Units 2 and 3 Recirculation Pumps.
Summary of Evaluation:
Recirculation Pump seal cooling and cleaning is accomplished by injecting cool water (Control Rod Drive seal purge) into the seal cartridge at the lower seal area. This cooling water is the source for flow through the pressure breakdown devices (PBDs), which are in parallel with each Recirculation Pump seal. The introduction of foreign material into the second stage seal PBD causes a reduction in flow, an increase in pressure, and an increase in seal temperature. This results in a reduction in seal life. In order to extend the seal life (prevent a unit shutdown), during this condition, a supplemental bleed-off flow path using the second stage seal pressure indicator line to a clean radwaste drain in the A/C Core Spray Triangle room can be used. Procedure AO 2A.16-2(3) is the Operations procedure used to control second stage seal pressure.
This activity uses the second stage seal pressure indicating instrument line to act as the flow path for the supplemental bleed-off flow. This pressure sensing line starts at the recirculation pump second stage seal area goes through a primary containment penetration and passes an excess flow check valve, and terminates in the A/C Core Spray Triangle Room at the pressure transmitter (PT) and pressure indicator (PI). Downstream of the PI/PT are normally closed valves. By opening/throttling these valves, a flow path is established. This piping discharges into a clean radwaste drain in the A/C Core Spray Triangle Room. During normal operations, with this supplemental bleed-off line in service, CRD water flow would be flowing out of the throttled valve into the clean radwaste drain. However, during abnormal/accident conditions when CRD seal purge flow is lost and RBCCW seal cooler cooling is lost (both non-safety functions), reactor water would be flowing through this supplemental bleed-off line. This water will flash to steam and enter the A/C Core Spray Triangle Room.
Since the environmental conditions in the A/C Core Spray Triangle rooms will be worse during abnormal/accident conditions when supplemental bleed-off is being used (compared to when not used),
this is considered an adverse change. The 50.59 Evaluation concluded that using Operations procedure AO 2A.16-2(3) would not impact any safety analysis or evaluation in the UFSAR. Use of this procedure does not affect any of the accident initiators in the plant and therefore does not increase the probability of an accident. Even though the environmental conditions are adversely impacted, the 10CFR50.59 Evaluation concludes that the equipment in the room credited to function during an accident remains Environmentally Qualified. Therefore, using AO 2A-16-2(3) will not increase the likelihood of malfunction of equipment important to safety. The increase in primary containment to secondary containment leakage remains below the La allowed limit. The increase in consequences, due to the increase in primary containment to secondary containment leakage, was shown to be negligible, well within the 10% margin to the allowable limit. Therefore, the consequences of an accident and the consequences of a malfunction of equipment are not more than minimal. Accidents of a different type and malfunctions of equipment with 7
2007-2008 Biennial 10CFR 50.59 and 10CFR 72.48 Reports a different result were not created. Using AO 2A-16.2(3) to control second stage seal pressure does not change any DBLFB or cause a DBLFB to be altered. The methodology used to in performing these evaluations is in accordance with methods described in the UFSAR.
Title:
Drywell Equipment Drain Sump Temporary Logic Reconfiguration Units Affected: 2 Year Implemented: 2008 Brief
Description:
The B Drywell Equipment Drain Pump was not providing adequate flow and the main control room operators were receiving an annunciator on every other pump out. This activity temporarily altered the logic for the two 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 setpoint. The annunciator will have a time delay added to prevent an alarm each time the pump operates. The anunnciator will come in if the pump cannot adequately reduce sump level.
Summary of Evaluation:
This activity removes the pump that is not operating and causes the operating pump to start each time on the high-high setpoint. The Drywell Equipment Drain Pumps and associated logic do not perform or support any safety related function. No safety analyses are impacted by this activity. This change does not interface with the flow monitoring from the equipment drains and does not affect the primary containment isolations for the sump drains. The performance of this activity resulted in temporarily reconfiguring the Unit 2 Drywell Equipment Drain Sump Pump logic. This involved a change to equipment that adversely affects a UFSAR described design function. The pump logic is an UFSAR described design function in UFSAR Section 4.10 as a result of the description of the alternating pump start logic.
The 50.59 Evaluation determined that this temporary change 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. It does not increase the likelihood of occurrence of a previously evaluated malfunction of an SSC important to safety because the affected equipment does not interfere with any previously evaluated. It does not increase the consequences of a previously evaluated malfunction of equipment important to safety because there are no consequences associated with the drywell sump pumps. It does snot 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. It 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 activity.
Title:
Spent Fuel Pool Rack Criticality Analysis Methodology Change Units Affected: 2&3 Year Implemented: 2008 Brief
Description:
The proposed activity is the incorporation of an updated Spent Fuel Pool (SFP) storage rack criticality analysis into the Peach Bottom Units 2 and 3 design bases. The updated analysis, as documented in the below Reference 1 and 2 8
2007-2008 Biennial 10CFR 50.59 and 10CFR 72.48 Reports reports, employs state of the art analytical methods and explicitly accounts for the current physical condition of the Peach Bottom racks and the most limiting fuel designs currently in storage. The analysis supports continued operation of the Peach Bottom SFP racks with pool average Boraflex panel Boron-10 aerial density losses of up to 15.2%.
Reference 1: Northeast Technology Corporation Report No. NET-264-02, "Criticality Analysis of the Peach Bottom Spent Fuel Racks for GNF2 Fuel with Boraflex Panel Degradation Projected to May 2012", Revision 1, June 20, 2008 Reference 2: GNF Report 0000-0035-7327-SFP, "GNF2 Spent Fuel Storage Rack Criticality Analysis for Peach Bottom Atomic Power Station Units 2 & 3", Revision 2, June 2008.
Summary of Evaluation:
The Peach Bottom spent fuel storage racks utilize Boraflex as a neutron absorber material for reactivity control. The Boraflex material is degrading with age and irradiation. To extend the service life of the racks a new analysis that accounts for actual rack conditions and more realistic fuel loadings has been performed.
The proposed, updated analysis will ensure that the Peach Bottom 2 and 3 spent fuel pools' effective neutron multiplication factors are maintained within the requirements of Tech Spec 4.3.1.b limit of 0.95 under all normal operating conditions and postulated accident scenarios with up to 15.2% B-10 aerial density loss from the SFP rack Boraflex panels. This will effectively extend the service life of the existing Peach Bottom 2 and 3 SFP rack by approximately 4 years. This activity does not impact the physical configuration or operation of any plant SSCs. The revised design basis will continue to assure compliance will all regulations governing SFP criticality.
The proposed activity does implement an alternative methodology in the criticality analysis of the Peach Bottom SFP racks as described in UFSAR Section 10.3.4. This methodology is not currently discussed in the existing UFSAR. The 50.59 evaluation concluded that the proposed updated SFP rack criticality analysis does not constitute a departure from a method of evaluation described in the FSAR used in establishing the design basis or in the safety analysis. This conclusion is based on the argument that the methods employed in the subject analysis have been either generically approved or specifically approved by the NRC for other licensees for the same application. This change is not a departure from an approved method of evaluation because it has been determined that the method is appropriate for the intended application, the terms and conditions for its use as specified in a previous NRC-approved Safety Evaluation Report have been satisfied, and the method has been approved by NRC. The proposed activity will not, therefore, result in a departure from a method of evaluation described in the FSAR used in establishing the design bases or in the safety analyses.
There were no 1 OCFR 50.59 Evaluation Reports performed / implemented for Unit 1 during this reporting period.
End of 10CFR 50.59 Report 9
2007-2008 Biennial I0CFR 50.59 and 10CFR 72.48 Reports EXELON NUCLEAR PEACH BOTTOM ATOMIC POWER STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NO. 72-29 BIENNIAL 10CFR 72.48 REPORT JANUARY 1, 2007 THROUGH DECEMBER 31, 2008 10CFR 72.48 EVALUATION SUMMARIES There were no 10CFR 72.48 Evaluations performed / implemented during this reporting period.
End of IOCFR 72.48 Report 10
2007-2008 Biennial 10CFR 50.59 and 10CFR 72.48 Reports EXELON NUCLEAR PEACH BOTTOM ATOMIC POWER STATION UNIT 1, 2 AND 3 DOCKET NOS. 50-171, 50-277, and 50-278 COMMITMENT REVISION REPORT JANUARY 1, 2007 THROUGH DECEMBER 31, 2008 11
2007-2008 Biennial 10CFR 50.59 and 10CFR 72.48 Reports Letter Source: Letter to NRC dated 5/17/07 providing details on the B.5.b Phases 2 and 3 Mitigation Strategies, including Responses to Requests for Additional Information Exelon Tracking No.: T04634, T04636 & T04637 Nature of Commitment: Implement Spent Fuel Pool and Reactor /Containment Mitigation Strategies associated with the B.5.b Closure Process for Phases 1, 2, and 3 Summary of Justification:
The corrective actions taken were performed and the station is in compliance with NRC requirements.
Changes were made to the required equipment and system alignment for various mitigation strategies to address difficulties experienced during simulated implementation of the strategies, as well as, improvement opportunities. The changes continue to comply with the industry guidance established for the strategies.
Letter Source: Letter to NRC dated 1/24/92, Response to NRC Notice of Violation 91-30-01 concerning training for Instrumentation & Controls personnel Exelon Tracking No.: T01710, TO1750, T04657 Nature of Commitment: Provide Independent and Double Verification training to Instrumentation
& Controls personnel.
Summary of Justification:
A more robust training program exists including a standardized fleet procedure governing these activities.
Improved standards and practices within the station have addressed this issue and expectations are proceduralized within the Exelon standard documents. There is no longer a need for this commitment due to process expectation upgrades. This is a historical commitment. The corrective actions taken were effective and the station is in compliance with NRC requirements. There is no longer a need to track this commitment.
Letter Source: Licensee Event Report 2-87-05 involving unacceptable local leak rate tests Exelon Tracking No.: T00216 Nature of Commitment: Provide tagging of both motor and incoming leads associated with 480V motor control centers to prevent errors in phase rotation alignment associated with motor control center maintenance.
12
2007-2008 Biennial 10CFR 50.59 and I0CFR 72.48 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 the operability maintenance process to ensure appropriate wiring of motor control centers are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 4/27/76 involving a response to NRC inspection report 76-08/07 Exelon Tracking No.: T01 975 Nature of Commitment: Improvement of tracking of surveillance tests that are required for unit outages.
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 the surveillance tracking process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 11/20/91 in Response to NRC inspection report 91-23/23 Exelon Tracking No.: T01 983 Nature of Commitment: Improvement of tracking of surveillance tests that are required for particular plant situations 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 the surveillance tracking process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 12/12/77 in Response to NRC inspection report 77-35/35 Exelon Tracking No.: TO1842 Nature of Commitment: Improvement of tracking of surveillance tests that are required for diesel generator fuel oil sampling Summary of Justification:
13
2007-2008 Biennial 10CFR 50.59 and IOCFR 72.48 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 the surveillance tracking process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 8/30/87 in Response to NRC inspection report 87-17/17 Exelon Tracking No.: T00365 Nature of Commitment: Improvement of software associated with the tracking of completed surveillance tests 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 the surveillance tracking process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 8/30/87 in Response to NRC inspection report 87-17/17 Exelon Tracking No.: T00364 Nature of Commitment: Improvement of controls for the tracking and coordination of partially completed surveillance tests 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 the surveillance tracking process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 12/14/92 in Response to NRC inspection report 92-14/14 Exelon Tracking No.: T03562 Nature of Commitment: Improvement of procedure writer's guide to reflect procedural requirements on data sheets, to improve human factoring of procedures and to better identify how procedures are to be implemented.
14
2007-2008 Biennial 10CFR 50.59 and IOCFR 72.48 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 the procedure revision process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 12/21/94 in Response to NRC inspection report 94-26/6 Exelon Tracking No.: T0569 Nature of Commitment: Improvement of surveillance test procedure writer's guide to address expectations for surveillance procedures and their relationship with operating procedures 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 the procedure revision process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 5/22/92 in Response to NRC Notice of Violation 92-07-03 Exelon Tracking No.: T01 974 Nature of Commitment: Improvement of controls for the tracking and coordination of surveillance tests required by the Inservice Testing Program 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 the surveillance tracking process have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: NRC Inspection Report 88-17/17 involving materials / warehouse procedures Exelon Tracking No.: T00377 Nature of Commitment: Revision of materials / warehouse procedures to include the verification of environmental conditions in the warehouse once per day 15
2007-2008 Biennial IOCFR 50.59 and 10CFR 72.48 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 the warehousing system have addressed this issue and are proceduralized within the Exelon standard documents. Additionally, physical upgrades have been made to the warehouse to address environmental conditions. There is no longer a need to track this commitment.
Letter Source: NRC Inspection Report 92-17/17 involving materials / warehouse storage of electrical equipment Exelon Tracking No.: T02766 Nature of Commitment: Revision of materials / warehouse procedures to include heightened controls for electrical 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 the warehousing system have addressed this issue and are proceduralized within the Exelon standard documents. There is no longer a need to track this commitment.
Letter Source: Letter to NRC dated 8/17/84 responding to NRC Inspection Report 84-14/127 involving inadequate corrective actions involving procurement procedures Exelon Tracking No.: T03558 Nature of Commitment: Inadequate corrective actions to ensure that appropriate end caps and covers are installed for stored piping 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 the warehousing system 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 16