NEI 99-04, (Pbaps), Units 1, 2, and 3 - Annual Commitment Revision Report for the Period 01/01/23 Through 12/31/23
| ML24031A015 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/31/2024 |
| From: | Henry D Constellation Energy Generation |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CCN: 24-01, NEI 99-04 (SECY-00-0045) | |
| Download: ML24031A015 (1) | |
Text
CCN: 24-01 January 31, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station (PBAPS), Units 1, 2, and 3 Facility Operating License No. DPR-12 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171. 50-277 and 50-278
Subject:
Annual Commitment Revision Report for the Period 01/01/23 through 12/31/23 Pursuant to SECY-00-0045 (NEI 99-04), enclosed is the 2023 Annual Commitment Revision Report. The enclosure describes commitments evaluated during the period that were either new (reopened), revised, or deleted.
If you have any questions or require additional information, please contact Tim Grimme at 717-456-4951.
Sincerely, David A. Henry Site Vice President Peach Bottom Atomic Power Station cc: NRC Regional Administrator - NRC Region I NRC Project Manager, NRR - PBAPS NRC Senior Resident Inspector - PBAPS W. DeHass, Commonwealth of Pennsylvania 023 Annual Commitment Revision Report
Enclosure - 2023 Annual Commitment Revision Report PEACH BOTTOM ATOMIC POWER STATION UNITS 1, 2, AND 3 DOCKET NOS. 50-171, 50-277, and 50-278 COMMITMENT REVISION REPORT JANUARY 1, 2023 THRU DECEMBER 31, 2023 Page 1 of 6
Enclosure - 2023 Annual Commitment Revision Report Commitment Source: NRC SER for PB License Amendments 248/251 Constellation Tracking Nos.: T03993 Post Accident Sampling Program TSTF-413 - REVISED Nature of Commitment: Peach Bottom implemented TSTF-413 deleting PASS requirements from the Technical Specifications (TS) as approved by the NRC in their Safety Evaluation Report (SER) associated with License Amendments 248/251 on 5/22/03. This licensing action allowed for the removal of previous Post Accident Sampling System (PASS) commitments and requirements as long as the following 3 commitments are met:
Commitment 1 - Maintain Contingency Plans for RCS Sampling Maintain contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, suppression pool, and containment atmosphere.
[Commitment actions 2 and 3 are unchanged]
Com mitment Summary of Justification: Since 2003, the contingency plans needed for obtaining and analyzing highly radioactive liquid and gaseous samples have been improved. Existing process and effluent sampling as well as portable sampling technology have been adopted and are controlled by CY-PB-180-906, CY-PB-180-907, CY-PB-180-911, CY-PB-180-912, CY-PB-180-914 and CY-PB-180-915. These methodologies and technology have been evaluated and approved for implementation throughout the Constellation fleet and the industry at large. The PASS is no longer considered the only means of satisfying the sampling and analysis contingency plan and will no longer be maintained by routine calibration and functional testing. For this reason, the implementing documents as listed above have replaced the PASS procedures. The changes do not alter the intent of the commitment only the means by which the commitment is implemented. This does not impact the description of the PASS in the UFSAR.
PBAPS UFSAR, Section 7.20.4.6 Coolant Sampling and Analysis Page 2 of 6
Enclosure - 2023 Annual Commitment Revision Report Commitment Source: Letter to NRC dated 12/29/76, Increased Turbine Bypass to the Condenser during Heatup - Feedwater Nozzle Thermal Cycling Reduction Constellation Tracking Nos.: T01854 (02701328-85) - DELETED Nature of Commitment: The reference commitment was generated as a response to events that were dispositioned through the station corrective action program.
Summary of Justification: Component Cyclic or Transient Limit Monitoring is a license obligation per TS 5.5.5. This program provides controls to track UFSAR Table 4.2.4, cyclic and transient occurrences to ensure that components ae maintained within design limits. Cyclic and Transient occurrences are monitored as required by NUREG/CR-6260 to ensure they remain under the design allowable cumulative usage factor (CUF). These actions exceed the intent of this historic commitment , obviating its necessity, in addition to it not meeting the definition of a Regulatory Commitment. The commitment has been deleted.
PBAPS UFSAR Table 4.2.4, Reactor Design Monitoring Locations (60-YEAR LIFE) Selected For Cycle Based Fatigue Monitoring PBAPS TS 5.5.5, Component Cyclic or Transient Limit Program Commitment Source: LETTER TO NRC DATED 07/26/92, Response to NRC Inspection Report 77-19/21; Foreign Material on Fuel Bridge Constellation Tracking Nos.: T01852 (02701328-84) - DELETED Nature of Commitment: This commitment was generated as a response to events that were dispositioned through the station corrective action program. A procedure (FH-6C) was revised to state the refueling supervisor will assure that there is no material on the bridge that is an undue risk for foreign material (FM) intrusion into the vessel.
Summary of Justification: Since 1992, the industry and the station have made foreign material exclusion a fundamental behavior and work practice. The company wide program for foreign material enclosure (FME) is administered by procedure MA-AA-716-008. Safety and integrity of nuclear fuel cladding is an obligation of all industry and station staff to prevent fuel failures and ensure effluents and exposure to our employees and the public are kept as low as reasonably achievable. The commitment does not satisfy the definition of a Regulatory Commitment and has been deleted.
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Enclosure - 2023 Annual Commitment Revision Report Commitment Source: LTR TO NRC, 01/07/91, RESPONSE TO NOV (90-18/18)
Constellation Tracking Nos.: T01020 (02701328-66) - DELETED Nature of Commitment: Process methods to ensure proper cold shutdown testing is performed were evaluated and the methods implemented to perform expanded relief valve testing following any setpoint test failure.
Summary of Justification: The commitment was generated as a response to events that were dispositioned through the station corrective action program. The requirements for testing scope expansion for safety relief valves is a license obligation as controlled by the In-Service Testing program to satisfy the requirements of NUREG-1482, 10CFR50.55(a), and ASME OM code. This item does not meet the definition of a Regulatory Commitment and has been deleted.
PBAPS Units 2 and 3 procedure(s): ER-AA-321-1002, ER-AA-321-1005, ER-PB-321-1000 Commitment Source: PB LER 2-90-021, Plant Shutdown Required Due to Inoperable Reactor Water Level Instrumentation Constellation Tracking Nos.: T00764 (02701328-48) - DELETED Nature of Commitment: Instrumentation which require daily channel checks will have their acceptance criteria tightened, where appropriate to provide early indication of instrument issues.
Summary of Justification: This action pre-dates the implementation of the instrument setpoint control program (IISCP). Since this action was completed, Technical Specification and important to safety instrument calibration tolerance requirements, Instrument loop uncertainty calculations, are controlled by formal program documents and are part of the station design bases in the form of calculations. Revision and changes to instrument ranges, scaling, and calibration set points, cannot be performed without applying a rigorous configuration change process under the auspices of 10 CFR 50.59. These actions exceed the intent of this historic commitment, obviating its necessity, in addition to not meeting the definition of a Regulatory Commitment. The commitment has been deleted.
PBAPS Units 2 and 3 procedures: CC-AA-103-2001 Instrument Setpoint Change Control Page 4 of 6
Enclosure - 2023 Annual Commitment Revision Report Commitment Source: PB LRA, APPENDIX A AND B Section B.2.9 Constellation Tracking Nos.: T04342 (2701330-64) - REVISED Nature of Commitment: Fire Protection activities for managing aging effects in the Fire Protection systems, provide for inspections, system monitoring, and/or system performance tests.
Summary of Justification: Implementing document updated: ST-O-37B-325-2 was DELETED and RT-O-37B-325-2 was added. This commitment has been revised.
PBAPS Units 2 and 3 procedures: RT-O-37B-325-2, RECIRC PUMP MG SET LUBE OIL PUMP ROOM SPRINKLER SYSTEM ACTUATION Commitment Source: SBO Rule Implementation RAI Response NRC Letter 10/23/1992 Constellation Tracking Nos.: T04082 (02701330-15) - Letter to NRC Concerning Station Blackout - NEW COMMITMENT (REOPENED)
Nature of Commitment: Letter to NRC concerning commitments made associated with Station Blackout (SBO) in response to request for additional information (RAI)
Question 9, Item 2 states that testing will be done approximately once every two years to approximately 7000 KW.
Summary of Justification: The 2023 PB NRC biennial Problem Identification & Resolution inspection identified less than adequate evaluation and justification for closing this CT. CA 04698520-02 has directed processing a commitment change evaluation to re-establish this CT.
Engineering review as documented on 04673392-03 concludes that there is no combination of current SBO maintenance strategy activities that fulfill the testing requirements as agreed to in the commitment bases letter, or as prescribed in Regulatory Guide 1.155, NUMARC 87-00 and 10 CFR 50.63. Demonstration of design bases capability through cable loading to rated conditions is required.
Therefore, the station commitment to periodically demonstrate the SBO line capability has been restored. A new commitment has been created (reactivated old CT # and ATI).
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Enclosure - 2023 Annual Commitment Revision Report Commitment Source: Reply to a Notice of Violation (NOV) - NOV 05000277,05000278/2023010-01 [ML23286A001]
Constellation Tracking Nos.: 02701385-45 -- NEW Nature of Commitment: Constellation Energy Generation, LLC, will develop and establish corrective actions to address the erosion of structural backfill in the pipe trench on the West side of the site.
Summary of Justification: Investigative product 04424065-02 was revised and approved on 11/27/2023. The investigative product concluded the cause of the soil erosion west of the plant is due to a lack of water management in the area. Two corrective actions have been created to address this.
CA 04424065-25 (due 06/30/2025) requires installation of a permanent yard drain sump modification to replace the system currently installed under temporary configuration change EC 638552.
The installed EC is also classified as a completed CA and acts as a bridging strategy to maintain the water table at the desired elevation until the permanent modification can be completed.
CA 04424065-24 (due 12/31/2024) requires removal of a blockage present in the storm drain system west of the plant.
The development and assignment of these corrective actions establishes compliance with the expectations of PI-AA-125 and 10 CFR Appendix B Criterion XVI.
End of Commitment Change Report Page 6 of 6