ML091260524

2008 Regulatory Commitment Change Summary Report

ML091260524
Person / Time
Site:	Dresden
Issue date:	04/27/2009
From:	Hanley T Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SVPLTR #09-0014
Download: ML091260524 (4)

Text

Exel@nExelon Generation Company, LLC www.exeloncorp.com NUclear Dresden Nuclear Power Station 6500 North Dresden Road Morris, IL 60450-9765 April 27, 2009 SVPLTR: #09-0014 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 Nuclear Docket Nos. 50-237 and 50-249

Subject:

2008 Regulatory Commitment Change Summary Report Please find enclosed the 2008 Commitment Change Summary for Dresden Nuclear Power Station as referenced in Attachment A. Revisions to docketed regulatory correspondence were processed using Nuclear Energy Institute's (NEI) 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes", dated July 1999.Should you have any questions concerning this summary, please contact Mr. Stephen Taylor, Regulatory Assurance Manager at 815-416-2800.

Respectfully, Site Vice President Dresden Nuclear Power Station

Enclosure:

Attachment A: Dresden Nuclear Power Station Commitment Change Summary for 2008 cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector, Dresden Nuclear Power Station/c t lt4<,

Attachment A Dresden Nuclear Power Station Commitment Change Summary for 2008 Commitment Date of Original Original Commitment Revised Commitment Basis For Revision Revision Commitment Document Tracking No. Revision 08-01 1/29/08 EGC Letter RS- EGO will continue to conduct daily Revised commitment letter, RS- The Unit 2 and 3 Steam Dryers were 06-015, dated monitoring of moisture carryover and 07-053, dated April 20, 2007 did replaced in 2007 and 2008 respectively.

Both January 26, 2006. other key reactor and plant not include a commitment to units have shown <0.04% moisture carryover parameters while operating at full conduct daily moisture carryover (MCO) since installing the new steam dryers.power at Dresden Nuclear Power monitoring.

The Engineering Department completed an Station (DNPS) Units 2 and 3, and Percent moisture carryover will Engineering Change evaluation, EC 366106 Quad Cities Nuclear Power Station now be determined per current Dresden Steam Dryer Monitoring Plan (QCNPS) Units 1 and 2, to provide recommended guidance, e.g. Following Replacement, to provide guidance an early indication of potential dryer BWRVIP-139.

Frequency will be for steam dryer performance.

The conclusion structural integrity issues. controlled by station procedures.

of the evaluation is that MCO monitoring can now be conducted in accordance with BWRVIP-139.

The current guidance in BWRVIP-139 is to sample for MCO on a weekly basis.08-02 2/28/08 Letter RS-03-001, Current program is credited.

Procedure ER-AA-2030, This revised wording provides more Letter from J. Procedure ER-AA-2030, attachment attachment A, Checklist wording prescriptive guidance to check for corrosion.

Benjamin to NRC, A, Checklist states ":No evidence of has been revised as follows: Application for unusual corrosion or overheating Renewed (blister, discoloration)".

No evidence of overheating Operating (blister, discoloration).

Licenses, section B.1.12 No evidence of corrosion on external surfaces (piping, bolting, equipment/components etc).I Attachment A Dresden Nuclear Power Station Commitment Change Summary for 2008 Commitment Date of Original Original Commitment Revised Commitment Basis For Revision Revision Commitment Document Tracking No. Revision 08-03 3/14/08 RS-04-020, Exelon has committed to Specific inspection frequencies Eddy current testing has been completed on Attachment Item implementing a Dresden plant stated in the corrective action both Unit 2 Isolation Condenser tube bundles.44 Heat specific, non-NUREG 1801, Heat program are subject to change as This was the first time eddy current testing Exchanger Test Exchanger Test and Inspection long as they remain consistent was performed since the Isolation Condenser and Inspection Activities Aging Management with the existing program was installed

(>35 years) and no tubes Program (AMP) that manages loss commitment as reflected in the required plugging.

Therefore it is concluded ATI 101522-45 of material, cracking, and buildup of February 3, 2004 letter (RS that the material condition on the Unit 2 deposits in heat exchangers in the 020) from Patrick R. Simpson, Isolation Condenser tube bundles is very scope of license renewal that are not Exelon, to USNRC titled, good and the eddy current testing frequency tested and inspected by the Open- Consolidated List of Commitments can be adjusted in accordance with the Cycle Cooling Water System for License Renewal, and the company's existing equipment reliability (B.1.13) or the Closed-Cycle Cooling program posted in the Electronic procedures and processes.

Water System (B.1.14) AMP. The Data Management System augmentation activities identified in (EDMS) under License Renewal.NUREG-1801, lines IV.C1.4-a and IV.C1.4-b to manage loss of material and cracking for the Dresden isolation condensers are included in this AMP.The Dresden Heat Exchanger Test and Inspection Activities AMP activities include performance monitoring and periodic inspections (condition monitoring) to manage loss of material, cracking and buildup of deposit aging effects.Loss of material and cracking are detected through visual inspections and NDE. Buildup of deposit is detected using a combination of system and component performance testing and component visual inspections.

9 Attachment A Dresden Nuclear Power Station Commitment Change Summary for 2008 Commitment Date of Original Original Commitment Revised Commitment Basis For Revision Revision Commitment Document Tracking No. Revision 08-04 1/27/09 Letter from R.F. On-line leakage monitoring systems Delete the requirement to monitor BWR Owners Group recommended newer Janecek , CeCo to consisting of thermocouples feedwater temperature via UT techniques that are now available as D. Eisenhut, NRC, installed on feedwater lines will leakage monitoring system. discussed in GE-NE-523-A71-0594, rev 0, regarding NUREG address the problems of cracking of Alternate BWR Feedwater Nozzle Inspection 0619 Feedwater and CRD nozzles on Requirements.

These current commitments Reactor Pressure Vessels recommendations that have been accepted dated 2/23/81. by the NRC no longer recommend installing thermocouples for leakage monitoring.

Thermocouples were unreliable in operation and will be removed.3