IR 05000454/2017009: Difference between revisions

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{{Adams
{{Adams
| number = ML18204A144
| number = ML18313A121
| issue date = 07/23/2018
| issue date = 11/09/2018
| title = Withdrawal of Non-Cited Violation 05000454/2017009-01; 05000455/2017009-01
| title = Errata - Byron Station, Units 1 and 2 - Evaluations of Changes, Tests, and Experiments Baseline Inspection Report 05000454/2017009; 05000455/2017009
| author name = West K S
| author name = Heck J K
| author affiliation = NRC/RGN-III
| author affiliation = NRC/RGN-III/DRS
| addressee name = Kanavos M E
| addressee name = Hanson B C
| addressee affiliation = Exelon Generation Co, LLC
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000454, 05000455
| docket = 05000454, 05000455
| license number = NPF-037, NPF-066
| license number = NPF-037, NPF-066
| contact person = Giessner J B
| contact person =  
| case reference number = EA-17-138
| document report number = IR 2017009
| document report number = IR 2017009, IR 2017009-01
| document type = Inspection Report, Letter
| document type = Letter
| page count = 13
| page count = 4
}}
}}


Line 19: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, ILLINOIS 60532-4352 July 23, 2018  
{{#Wiki_filter:
[[Issue date::November 9, 2018]]


EA-17-138
Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555


Mr. Mark Kanavos Site VP, Byron Generating Station 4450 North German Church Rd
SUBJECT: ERRATA-BYRON STATION, UNITS 1 AND 2
-EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000454/2017009; 05000455/2017009 Dear Mr. Hanson
: On May 19, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of changes, Tests, and Experiments inspection at your Byron Statio On June 29, 2017
, the NRC issued Inspection Report 05000454/2017009; 05000455/201700 This original inspection report documented one traditional enforcement Severity Level IV violation with an associated finding in which the NRC treated as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Polic In a letter dated July 23, 2018, (ML18204A144) the NRC withdrew the NCV based on an independent panel's revie The purpose of this letter is to re-issue the NRC Inspection Report 05000454/2017009; 05000455/2017009 in its entiret The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your licens The inspectors reviewed selected procedures and records, observed activities, and interviewed personne No findings or violations of more
-than-minor significance were identified during this inspectio B. Hanson -2- This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading
-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."


Byron, IL 61010-9794
Sincerely,/RA/ Jared Heck, Acting Deputy Director Division of Reactor Safety Docket Nos. 50
-454; 50-455 License Nos. NPF
-37; NPF-66


SUBJECT: WITHDRAWAL OF NON-CITED VIOLATION 05000454/2017009-01; 05000455/2017009-01
===Enclosure:===
IR 05000 454/20 1 7009; 05000 455/20 1 7009 cc: Distribution via LISTSERV


==Dear Mr. Kanavos:==
=SUMMARY=
On July 31, 2017, Exelon Generation Company (EGC), LLC, provided a written response to the U.S. Nuclear Regulatory Commission (NRC) Inspection Report 05000454/2017009; 05000455/2017009 issued on June 29, 2017, concerning an Evaluations of Changes, Tests, and Experiments Inspection completed at Byron Station, Units 1 and 2. Specifically, the letter contested Non-Cited Violation (NCV) 05000454/2017009-01; 05000455/2017009-01 associated with the failure to perform an evaluation of a change to the facility as described in the Updated Final Safety Analysis Report (UFSAR) pursuant to Title 10 of the Code of Federal Regulations (CFR), paragraph 50.59(d)(1). On December 21, 2017, the NRC responded to your letter contesting the violation (Agenc y Documents Access and Management System (ADAMS) Accession No. ML17355A561). In that letter the NRC determined that the violation was valid, but we articulated that the initially-documented NCV needed additional information to justify the NCV. On February 8, 2018, in a letter from Exelon to the Director of the Office of Enforcement, you sought to appeal that decision, and provided additional information. In a letter to Exelon on April 8, 2018 (ADAMS ML18100A222), the NRC agreed to review the issue as an initial appeal of Region III's December decision based on the change from the original violation and the new information Exelon provided. This letter provides the decision based on our review.
Inspection Report 05000 454/20 1 7009, 05000 455/20 1 7009; 05/15/2017
-06/01/2017
; Byron Station, Units 1 and 2
; Evaluations of Changes, Tests, and Experiments.


The review was conducted by an independent NRC panel, which considered relevant information on this matter to date. The relevant information considered included: applicable guidance documents concerning the Surveillance Frequency Control Program (SFCP),
This report covers a one-week announced Evaluations of Changes, Tests, and Experiments baseline inspection. The inspection was conducted by Region III based engineering inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG
10 CFR 50.59 process, and the licensee's commitment management process; all docketed correspondence on the violation; input from NRC subject matter experts in various offices; participation in the Category 2 public meeting with the Nuclear Energy Institute (NEI) regarding the SFCP on March 20, 2018; and interviews with the key NRC and Exelon staff involved in the assessment of the violation, assessment of the disputed violation, and/or dispute of the violation.
-1649, "Reactor Oversight Process," Revision 6, dated July 2016.


In September 2000, the NRC endorsed NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes" (Regulatory Information Summary 00-017, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff"). In November 2000, the NRC endorsed NEI 96-07, Revision 1, "Guidelines for 10 CFR 50.59 Evaluations" (NRC Regulatory Guide 1.187). By letter dated September 19, 2007, the NRC found NEI 04-10, Revision 1, "Risk-Informed Technical Specification Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," acceptable for referencing by licensees proposing to amend their Technical Specifications (TS) to establish a SFCP (ADAMS ML072570267).
3


By letter dated February 24, 2011, the NRC issued Byron Amendment No. 171 which relocated specific surveillance frequencies in Byron's TS to a licensee-controlled program (i.e., the SFCP). For these relocated surveillance frequencies, the TS were revised to state that the surveillance will be performed "in accordance with the surveillance frequency control program." As part of this amendment, Section 5.5.19, "Surveillance Frequency Control Program," was added to the TS, which requires changes to the relocated surveillance frequencies to be made in accordance with NEI 04-10, Revision 1.
=REPORT DETAILS=


As part of Byron Amendment No. 171, specific surveillance frequencies associated with the testing of emergency diesel generators (EDGs) were relocated to the SFCP. In February 2014, Byron used their NRC-approved SFCP, including the NEI 04-10 guidance, to evaluate and control a frequency change for performance of an EDG and integrated safeguards loss of offsite power/engineered safety features surveillance test from "18 months" to "18 months on a staggered test basis."
==REACTOR SAFETY==


In assessing the new information provided for the disputed violation, the NRC independent review panel noted one main point of disagreement between the NRC and Exelon. Specifically, the main issue occurs in Step 2 of the NEI 04-10 process in assessing whether the frequency change represents a change in a regulatory commitment. In particular, Byron Updated Final Safety Analysis Report (UFSAR) Appendix A, "Application of NRC Regulatory Guides,"
===Cornerstone:===
originally stated that Byron complied with Institute of Electrical and Electronics Engineers Standard 387-1984, "IEEE Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations," and supplemental regulatory positions in Regulatory Guide 1.9, "Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants," Revision 3, which require licensees to perform the EDG surveillances during every refueling outage. To resolve this apparent point of confusion, the review panel stepped through the NEI 04-10 process and the related NRC-endorsed industry guidance
Initiating Events, Mitigating Systems, and Barrier Integrity


documents (NEI 99-04 and NEI 96-07).
{{a|1R17}}
==1R17 Evaluation==


In NEI 04-10 Step 2, a check is made to determine if the applicable regulatory commitments to the NRC can be changed. Evaluating changes to regulatory commitments is a separate activity based on a method acceptable to the NRC for managing and changing regulatory commitments (e.g., NEI 99-04). NEI 99-04 Section 3.1, "Definitions," defines a regulatory commitment as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. A regulatory commitment is an intentional undertaking by a licensee to (1) restore compliance with regulatory requirements, or (2) complete a specific action to address an NRC issue or concern (e.g., generic letter, bulletin, order, etc.). The panel determined through review of NRR Office Instructions that Byron's UFSAR Appendix A is part of a mandated licensing bases document and not a set of regulatory commitments. In addition, the use of the SFCP to change surveillance frequencies was previously reviewed and approved by the NRC staff with Byron Amendment No. 171. Thus, there was no associated regulatory commitment to change under NEI 04-10 Step 2, and it was appropriate for the licensee to continue to step through the NEI 04-10 process to evaluate an EDG surveillance frequency change. The review panel noted that the licensee was addressing the associated EDG surveillance frequency change through an NRC approved change-control process (SFCP) specifically intended for that purpose. Following satisfactory completion of the SFCP evaluation process to approve the EDG surveillance frequency change, Exelon performed a 10 CFR 50.59 screening using its internal guidance. Specifically, in February 2014, Exelon's 50.59 screening (No. 6E-14-017)
s of Changes, Tests, and Experiments (71111.17 T)
determined that a 10 CFR 50.59 evaluation was not required. The review panel did not identify any regulatory obligations, additional mandated licensing bases documents, commitments, and/or UFSAR wording changes evaluated under this 10 CFR 50.59 screening that was not covered by the SFCP process. The review panel determined that a 10 CFR 50.59 evaluation was not required, because the NRC staff had prev iously granted the licensee authority, through Byron Amendment No. 171, to change the specific EDG surveillance frequencies in accordance with the SFCP.


Based on the independent panel's thorough review of the issue, the NRC has concluded that the 50.59 violation as written cannot be supported. Therefore, the NCV is hereby withdrawn, and we will modify our records accordingly.
===.1 Evaluation of Changes, Tests, and===


This letter will be made available electronically for public inspection and copying from ADAMS available at http://www.nrc.gov/reading-rm/adams.html and in the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Experiments


If you have any questions regarding this matter, please contact Mr. John Giessner at
====a. Inspection Scope====
The inspectors reviewed evaluations performed pursuant to Title 10 of the Code of Federal Regulations (CFR), Part 50, Section 59 to determine if the evaluations were adequate and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed screenings and applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:  the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change.


(630) 829-9800.
The inspectors used, in part, Nuclear Energy Institute (NEI) 96
-07 , "Guidelines for 10 CFR 50.59 Implementation
," Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000.


Sincerely,/RA/ K. Steven West Regional Administrator Docket Nos. 50-454; 50-455
The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments."


License Nos. NPF-37; NPF-66
This inspection constituted 23 samples of evaluations, screenings, and/or applicability determinations as defined in IP 71111.17-05.


cc: Distribution via LISTSERV Letter to from K. Steven West dated July 23, 2018
====b. Findings====
No findings or violations of significance were identified


SUBJECT: WITHDRAWAL OF NON-CITED VIOLATION 05000454/2017009-01; 05000455/2017009-01
==OTHER ACTIVITIES (OA)==
{{a|4OA2}}
==4OA2 Problem Identification and Resolution==


DISTRIBUTION: Jeremy Bowen Juan Peralta
===.1 Routine Review of Condition Reports===


RidsNrrDorlLpl3 RidsNrrPMByron Resource RidsNrrDirsIrib Resource
====a. Inspection Scope====
The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.


Steven West
====b. Findings====
No findings of significance were identified.


Darrell Roberts Jack Giessner
{{a|4OA6}}
==4OA6 Meetings==


Richard Skokowski Allan Barker DRPIII DRSIII ADAMS Accession Number ML18204A144 OFC RIII-ORA RI RIII-DNMS NRR OE OGC RIII/EICS RIII/ORA NAME JHeck:jc JSchoppy JGiessner BHolian 1 ABoland 2 MZobler 3 RSkokowski KJL for KSWest DATE 05/14/18 5/14/18 05/16/18 7/13/18 7/17/18 7/13/18 07/19/18 7/23/18 OFFICIAL RECORD COPY
===.1 Exit Meeting Summary===


1 NRR concurrence provided via e-ma il from M. Miller on July 13, 2018 2 OE concurrence provided via e-mail from M. Marshfield on July 17, 2018 3 OGC NLO provided via email from Sara Kirkwood on July 13, 2018
On November 8, 2018, the inspection results were presented to Ms. Z. Cox. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.
 
===.2 Interim Exit Meetings===
 
O n June 1, 2017, the inspector s presented the original inspection results to Mr. T. Chalmers, and other members of the licensee staff. The inspectors confirmed that none of the potential report input discussed was considered proprietary
. ATTACHMENT: 
 
=SUPPLEMENTAL INFORMATION=
 
==KEY POINTS OF CONTACT==
 
Licensee 
: [[contact::J. Bauer]], Corporate Licensing Engineer
: [[contact::T. Chalmers]], Plant Manager
: [[contact::G. Contrady]], Regulatory Assurance
Engineer
: [[contact::Z. Cox]], Regulatory Assurance
: [[contact::D. Gullott]], Corporate Licensing Manager
: [[contact::C. Keller]], Engineering Director
: [[contact::D. Spitzer]], Regulatory Assurance Manager
: [[contact::G. Wilhelmsen]], Senior Engineering Manager
: [[contact::K. Zlevor]], Senior Engineer
: [[contact::L. Zurawski]], Regulatory Assurance
U.S. Nuclear Regulatory Commission
: [[contact::R. Daley]], Branch Chief, EB3
: [[contact::C. Hunt]], Resident Inspector
: [[contact::J. McGhee]], Senior Resident Inspector
 
==LIST OF ITEMS==
OPENED, CLOSED
, AND DISCUSSED
None 
==LIST OF DOCUMENTS REVIEWED==
The following is a list of documents reviewed during the inspection.
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
: Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
: CFR 50.59 EVALUATIONS
: Number Description or Title Revision 6G-14-003 Implementation of WCAP
-15063-P-A, Revision 1, with Errata, "Westinghouse Improved Performance Analysis and Design Model (PAD 4.0)," and WCAP
-12610-P-A and GENPD
-404-P-A Addendum
: 2-A, "Westinghouse Clad Corrosion Model for ZIRLO and Optimized ZIRLO" 0 6G-14-004 Establishing a Nitrogen Blanket on the Volume Control Tank (VCT)
: 6G-15-004 Implement Use of Westinghouse SHIELD for Use in Reactor Coolant Pump Seal Configurations
: 6G-16-001 Remove AF Diesel Air Intake Elbow and Blank Off TB Air Intake
: 10
: CFR 50.59 EVALUATIONS
: Number Description or Title Revision 6G-16-006 Reroute AF Diesel Pump Combustion Air Intake to 364' General Area Unit 1 & 2
: 6G-16-007 Temporarily Defeat FW Water Hammer Prevention System (WHPS) FW Isolation Signals During Normal Power Operation For Steam Generators 2A/2B/2C/2D
(EC 406958) 0 6G-16-008 Appendix J Scope Reduction
: 6G-17-001 Lost SFP Crimps and RVLIS Pins
: 10
: CFR 50.59 SCREENINGS
: Number Description or Title Revision 6D-15-002 UFSAR Update to Reflect Current LOCA Design Inputs for Unit 2
: 6D-15-010 Alternate Main Control Room Ventilation
: 6D-15-016 LCOAR ESF Battery Room Ventilation
: 6D-15-025 Revision to BCB
-2 Table 1-6 to Add Most Reactive Stuck Rod Worths to Use in the Event of Untrippable RCCAs
: 6E-14-017 Revise Diesel Generator and Integrated Safeguards LOOP/ESF Surveillance Test Surveillance Frequency from 18 Months to 18 Months Staggered
: 6E-14-020 Operation of 1A SX Pump With One
-Half of a Cubicle Cooler
: 6E-14-040 Drill Holes in Line 2CD31AD t
o Stop Crack Propagation
: 6E-14-042 Modify Logic for Unit 2 Condensate and Condensate Booster Pumps Lube Oil Pressure Switches (EC
: 398037) 0 6E-14-046 Modify Logic for Unit 1 Condensate and Condensate Booster Pumps Lube Oil Pressure Switches (EC
: 398036) 0 6E-14-052 SSPS Wiring Changes Needed to Address Westinghouse Technical Bulletin TB
-13-7 Solid State Protection System New Design Universal Logic Board and Safeguards Driver Board 48
: Vdc Input (EC 397531) 0 6E-14-060 Plant Barrier Impairment (Penetration
: 26087) 0 6E-15-035 Increase Pressurizer PORV Accumulator Tank Operating Pressure to Increase Margin for PORV Operation (Unit 1)
: 6E-16-001 UFSAR Update of the Diesel
-Generator Fuel Oil Storage and Transfer System Description
: 6E-16-061 Technical Requirements Manual (TRM) Technical Surveillance (PR No. 16-009) 0 6E-16-097 Appendix J Scope Reduction
: CALCULATIONS
: Number Description or Title Revision
: BY-13-003 Diesel Generator and Integrated Safeguards LOOP/ESF Surveillance Test Interval Evaluation
: BYR 10-053/
: BRW-10-0033-1 Calculation Feedwater Pressure Uncertainty for Input to LEFM CheckPlus System
: BYR10-054
: ER-800 Bounding Uncertainty Analysis for Thermal Power Determination at Byron Unit 1 Using the LEFM CheckPlus System 3 BYR10-055
: ER-801 Bounding Uncertainty Analysis for Thermal Power Determination at Byron Unit 2 Using the LEFM CheckPlus System 2
: CORRECTIVE ACTION PROGRAM DOCUMENTS
: INITIATED DURING INSPECTION
: Number Description or Title Date
: 4002071 50.59 Screening Form for BOP DO
-16 Missing
: 04/24/2017
: 4017182 NRC Question on 50.59 Screening for DRP 15
-073 06/01/2017
: CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
: Number Description or Title Date
: 1500984 2B DG Shut Down Earlier than Desired During Sequence Test
: 04/12/2013
: 1500993 2B DG Sequence Times Acceptance Criteria not Met 04/12/2013
: 1673329 Concern About Testing Performed For HELB Dampers
: 06/19/2014
: 2467656 Issues Identified in Engineering Evaluation
: 03/12/2015
: 2496142 CDBI - 50.59 And DRP Did not Explicitly Evaluate GDC 5
: 05/05/2015
: 27378
: MCC 234V4 not Energized Subsequent U
-2 Rx Trip 10/12/2016
: 3978965 2017 50.59 FASA Identifies 50.59 Requires Revision
: 2/27/2017
: DRAWINGS Number Description or Title Date or Revision M-129, Sheet 1C
: Diagram of Containment Spray, Unit 2
: 09/01/2000
: M-138, Sheet 2
: Diagram of Chemical & Volume Control & Boron Thermal Regen, Unit 2
: 09/22/2000
: M-46, Sheet 1C Diagram of Containment Spray, Unit 1
: 01/08/1998
: M-50, Sheet 1B
: Diagram of Diesel Fuel Oil
: AP M-64, Sheet 2
: Diagram of Chemical & Volume Control & Boron Thermal Regen, Unit 1
: 03/05/1998
: M-64, Sheet 5
: Diagram of Chemical & Volume Control & Boron Thermal Regen, Unit 1
: 2/24/1999
: ENGINEERING CHANGES
: Number Description or Title Date or Revision
: 397531 SSPS Wiring Changes Needed to Address Westinghouse Technical Bulletin TB
-13-7 Solid State Protection System Logic Board and Safeguards Driver Board 48
: Vdc Input 0
: 398036 Modify Logic for Unit 1 Condensate and Condensate Booster Pumps Lube Oil Pressure Switches
: 398037 Modify Logic for Unit 2 Condensate and Condensate Booster Pump Lube Oil Pressure Switches
: 406958 Temporarily Defeat FW Water Hammer Prevention System (WHPS) FW Isolation Signals During Normal Power Operation for Steam Generators 2A/2B/2C/2D
: 617642 Temporarily Defeat FW Water Hammer Prevention System (WHPS) FW Isolation Signals During Normal Power Operation for Steam Generators 2A/2B/2C/2D
(Braidwood)
: 01/09/2017
: OTHER DOCUMENTS
: Number Description or Title Date
: LER 455- 2016-001 Manual Reactor Trip due to Circuit Breaker Failure that Caused Actuation of Feedwater Hammer Prevention System with Automatic Isolation of Feedwater to Two Steam Generators and Low Steam Generator Levels
: 10/12/20 16 PR No. 16 009
: Revision to Technical Requirements Manual (TRM) Technical Surveillance Requirement TSR 3.3.k.2 LEFM Channel Calibration
: 07/12/20 16
: TB-13-7 Westinghouse Technical Bulletin Solid State Protection New Design Universal Logic Board and Safeguards Driver Board Vdc Input 12/10/20 13
: PROCEDURES
: Number Description or Title Revision 1BOSR 4.11.3-1 Unit One Pressurizer PORV Accumulator Pressure Decay Test
: 2BGP 100-1 Plant Heatup
: 2BGP 100-3 Power Ascension
: 2BGP 100-4 Power Descension
: 2BGP 100-4T4 Reactor Trip Post Response Guideline 7 BAR 1-12-D7 PZR PORV SUP PRESS HIGH LOW
: ER-AA-425 Implementation of the Technical Specification Surveillance Frequency Control Program
: PROCEDURES
: Number Description or Title Revision
: ER-AA-425-1005 Monitoring the Effects of Changes to the Surveillance Frequency Control Program (SFCP)
: LS-AA-104 Exelon 50.59 Review Process
: OP-MW-201-007 Fire Protection System Impairment Control
: RP-BY-301-1001 Radiological Air Sampling Program
==LIST OF ACRONYMS==
: [[USE]] [[D]]
CFR Code of Federal Regulations
IEEE Institute of Electrical & Electronic
s Engineers
: [[LOOP]] [[Loss of Offsite Power]]
: [[NEI]] [[Nuclear Energy Institute]]
: [[NRC]] [[U.S. Nuclear Regulatory Commission]]
: [[RG]] [[Regulatory Guide]]
: [[SDP]] [[Significance Determination Process]]
: [[SFCP]] [[Surveillance Frequency Control Program]]
: [[SSC]] [[Structure, System, or Component]]
STI Surveillance Test Interval
: [[UFSAR]] [[Updated Final Safety Analysis Report]]
}}
}}

Revision as of 04:44, 11 December 2018

Errata - Byron Station, Units 1 and 2 - Evaluations of Changes, Tests, and Experiments Baseline Inspection Report 05000454/2017009; 05000455/2017009
ML18313A121
Person / Time
Site: Byron  Constellation icon.png
Issue date: 11/09/2018
From: Heck J K
Division of Reactor Safety III
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2017009
Preceding documents:
Download: ML18313A121 (13)
v • d • e


Text

November 9, 2018

Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: ERRATA-BYRON STATION, UNITS 1 AND 2

-EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000454/2017009; 05000455/2017009 Dear Mr. Hanson

On May 19, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of changes, Tests, and Experiments inspection at your Byron Statio On June 29, 2017

, the NRC issued Inspection Report 05000454/2017009; 05000455/201700 This original inspection report documented one traditional enforcement Severity Level IV violation with an associated finding in which the NRC treated as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Polic In a letter dated July 23, 2018, (ML18204A144) the NRC withdrew the NCV based on an independent panel's revie The purpose of this letter is to re-issue the NRC Inspection Report 05000454/2017009; 05000455/2017009 in its entiret The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your licens The inspectors reviewed selected procedures and records, observed activities, and interviewed personne No findings or violations of more

-than-minor significance were identified during this inspectio B. Hanson -2- This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading

-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,/RA/ Jared Heck, Acting Deputy Director Division of Reactor Safety Docket Nos. 50

-454; 50-455 License Nos. NPF

-37; NPF-66

Enclosure:

IR 05000 454/20 1 7009; 05000 455/20 1 7009 cc: Distribution via LISTSERV

SUMMARY

Inspection Report 05000 454/20 1 7009, 05000 455/20 1 7009; 05/15/2017

-06/01/2017

Byron Station, Units 1 and 2
Evaluations of Changes, Tests, and Experiments.

This report covers a one-week announced Evaluations of Changes, Tests, and Experiments baseline inspection. The inspection was conducted by Region III based engineering inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 6, dated July 2016.

3

REPORT DETAILS

REACTOR SAFETY

Cornerstone:

Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluation

s of Changes, Tests, and Experiments (71111.17 T)

.1 Evaluation of Changes, Tests, and

Experiments

a. Inspection Scope

The inspectors reviewed evaluations performed pursuant to Title 10 of the Code of Federal Regulations (CFR), Part 50, Section 59 to determine if the evaluations were adequate and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed screenings and applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if: the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required; the safety issue requiring the change, tests or experiment was resolved; the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute (NEI) 96

-07 , "Guidelines for 10 CFR 50.59 Implementation

," Revision 1, to determine acceptability of the completed evaluations and screenings. The NEI document was endorsed by the NRC in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000.

The inspectors also consulted Part 9900 of the NRC Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments."

This inspection constituted 23 samples of evaluations, screenings, and/or applicability determinations as defined in IP 71111.17-05.

b. Findings

No findings or violations of significance were identified

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

.1 Routine Review of Condition Reports

a. Inspection Scope

The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting Summary

On November 8, 2018, the inspection results were presented to Ms. Z. Cox. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.

.2 Interim Exit Meetings

O n June 1, 2017, the inspector s presented the original inspection results to Mr. T. Chalmers, and other members of the licensee staff. The inspectors confirmed that none of the potential report input discussed was considered proprietary

. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Bauer, Corporate Licensing Engineer
T. Chalmers, Plant Manager
G. Contrady, Regulatory Assurance

Engineer

Z. Cox, Regulatory Assurance
D. Gullott, Corporate Licensing Manager
C. Keller, Engineering Director
D. Spitzer, Regulatory Assurance Manager
G. Wilhelmsen, Senior Engineering Manager
K. Zlevor, Senior Engineer
L. Zurawski, Regulatory Assurance

U.S. Nuclear Regulatory Commission

R. Daley, Branch Chief, EB3
C. Hunt, Resident Inspector
J. McGhee, Senior Resident Inspector

LIST OF ITEMS

OPENED, CLOSED

, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
CFR 50.59 EVALUATIONS
Number Description or Title Revision 6G-14-003 Implementation of WCAP

-15063-P-A, Revision 1, with Errata, "Westinghouse Improved Performance Analysis and Design Model (PAD 4.0)," and WCAP

-12610-P-A and GENPD

-404-P-A Addendum

2-A, "Westinghouse Clad Corrosion Model for ZIRLO and Optimized ZIRLO" 0 6G-14-004 Establishing a Nitrogen Blanket on the Volume Control Tank (VCT)
6G-15-004 Implement Use of Westinghouse SHIELD for Use in Reactor Coolant Pump Seal Configurations
6G-16-001 Remove AF Diesel Air Intake Elbow and Blank Off TB Air Intake
10
CFR 50.59 EVALUATIONS
Number Description or Title Revision 6G-16-006 Reroute AF Diesel Pump Combustion Air Intake to 364' General Area Unit 1 & 2
6G-16-007 Temporarily Defeat FW Water Hammer Prevention System (WHPS) FW Isolation Signals During Normal Power Operation For Steam Generators 2A/2B/2C/2D

(EC 406958) 0 6G-16-008 Appendix J Scope Reduction

6G-17-001 Lost SFP Crimps and RVLIS Pins
10
CFR 50.59 SCREENINGS
Number Description or Title Revision 6D-15-002 UFSAR Update to Reflect Current LOCA Design Inputs for Unit 2
6D-15-010 Alternate Main Control Room Ventilation
6D-15-016 LCOAR ESF Battery Room Ventilation
6D-15-025 Revision to BCB

-2 Table 1-6 to Add Most Reactive Stuck Rod Worths to Use in the Event of Untrippable RCCAs

6E-14-017 Revise Diesel Generator and Integrated Safeguards LOOP/ESF Surveillance Test Surveillance Frequency from 18 Months to 18 Months Staggered
6E-14-020 Operation of 1A SX Pump With One

-Half of a Cubicle Cooler

6E-14-040 Drill Holes in Line 2CD31AD t

o Stop Crack Propagation

6E-14-042 Modify Logic for Unit 2 Condensate and Condensate Booster Pumps Lube Oil Pressure Switches (EC
398037) 0 6E-14-046 Modify Logic for Unit 1 Condensate and Condensate Booster Pumps Lube Oil Pressure Switches (EC
398036) 0 6E-14-052 SSPS Wiring Changes Needed to Address Westinghouse Technical Bulletin TB

-13-7 Solid State Protection System New Design Universal Logic Board and Safeguards Driver Board 48

Vdc Input (EC 397531) 0 6E-14-060 Plant Barrier Impairment (Penetration
26087) 0 6E-15-035 Increase Pressurizer PORV Accumulator Tank Operating Pressure to Increase Margin for PORV Operation (Unit 1)
6E-16-001 UFSAR Update of the Diesel

-Generator Fuel Oil Storage and Transfer System Description

6E-16-061 Technical Requirements Manual (TRM) Technical Surveillance (PR No.16-009) 0 6E-16-097 Appendix J Scope Reduction
CALCULATIONS
Number Description or Title Revision
BY-13-003 Diesel Generator and Integrated Safeguards LOOP/ESF Surveillance Test Interval Evaluation
BYR 10-053/
BRW-10-0033-1 Calculation Feedwater Pressure Uncertainty for Input to LEFM CheckPlus System
BYR10-054
ER-800 Bounding Uncertainty Analysis for Thermal Power Determination at Byron Unit 1 Using the LEFM CheckPlus System 3 BYR10-055
ER-801 Bounding Uncertainty Analysis for Thermal Power Determination at Byron Unit 2 Using the LEFM CheckPlus System 2
CORRECTIVE ACTION PROGRAM DOCUMENTS
INITIATED DURING INSPECTION
Number Description or Title Date
4002071 50.59 Screening Form for BOP DO

-16 Missing

04/24/2017
4017182 NRC Question on 50.59 Screening for DRP 15

-073 06/01/2017

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number Description or Title Date
1500984 2B DG Shut Down Earlier than Desired During Sequence Test
04/12/2013
1500993 2B DG Sequence Times Acceptance Criteria not Met 04/12/2013
1673329 Concern About Testing Performed For HELB Dampers
06/19/2014
2467656 Issues Identified in Engineering Evaluation
03/12/2015
2496142 CDBI - 50.59 And DRP Did not Explicitly Evaluate GDC 5
05/05/2015
27378
MCC 234V4 not Energized Subsequent U

-2 Rx Trip 10/12/2016

3978965 2017 50.59 FASA Identifies 50.59 Requires Revision
2/27/2017
DRAWINGS Number Description or Title Date or Revision M-129, Sheet 1C
Diagram of Containment Spray, Unit 2
09/01/2000
M-138, Sheet 2
Diagram of Chemical & Volume Control & Boron Thermal Regen, Unit 2
09/22/2000
M-46, Sheet 1C Diagram of Containment Spray, Unit 1
01/08/1998
M-50, Sheet 1B
Diagram of Diesel Fuel Oil
AP M-64, Sheet 2
Diagram of Chemical & Volume Control & Boron Thermal Regen, Unit 1
03/05/1998
M-64, Sheet 5
Diagram of Chemical & Volume Control & Boron Thermal Regen, Unit 1
2/24/1999
ENGINEERING CHANGES
Number Description or Title Date or Revision
397531 SSPS Wiring Changes Needed to Address Westinghouse Technical Bulletin TB

-13-7 Solid State Protection System Logic Board and Safeguards Driver Board 48

Vdc Input 0
398036 Modify Logic for Unit 1 Condensate and Condensate Booster Pumps Lube Oil Pressure Switches
398037 Modify Logic for Unit 2 Condensate and Condensate Booster Pump Lube Oil Pressure Switches
406958 Temporarily Defeat FW Water Hammer Prevention System (WHPS) FW Isolation Signals During Normal Power Operation for Steam Generators 2A/2B/2C/2D
617642 Temporarily Defeat FW Water Hammer Prevention System (WHPS) FW Isolation Signals During Normal Power Operation for Steam Generators 2A/2B/2C/2D

(Braidwood)

01/09/2017
OTHER DOCUMENTS
Number Description or Title Date
LER 455- 2016-001 Manual Reactor Trip due to Circuit Breaker Failure that Caused Actuation of Feedwater Hammer Prevention System with Automatic Isolation of Feedwater to Two Steam Generators and Low Steam Generator Levels
10/12/20 16 PR No. 16 009
Revision to Technical Requirements Manual (TRM) Technical Surveillance Requirement TSR 3.3.k.2 LEFM Channel Calibration
07/12/20 16
TB-13-7 Westinghouse Technical Bulletin Solid State Protection New Design Universal Logic Board and Safeguards Driver Board Vdc Input 12/10/20 13
PROCEDURES
Number Description or Title Revision 1BOSR 4.11.3-1 Unit One Pressurizer PORV Accumulator Pressure Decay Test
2BGP 100-1 Plant Heatup
2BGP 100-3 Power Ascension
2BGP 100-4 Power Descension
2BGP 100-4T4 Reactor Trip Post Response Guideline 7 BAR 1-12-D7 PZR PORV SUP PRESS HIGH LOW
ER-AA-425 Implementation of the Technical Specification Surveillance Frequency Control Program
PROCEDURES
Number Description or Title Revision
ER-AA-425-1005 Monitoring the Effects of Changes to the Surveillance Frequency Control Program (SFCP)
LS-AA-104 Exelon 50.59 Review Process
OP-MW-201-007 Fire Protection System Impairment Control
RP-BY-301-1001 Radiological Air Sampling Program

LIST OF ACRONYMS

USE D

CFR Code of Federal Regulations

IEEE Institute of Electrical & Electronic

s Engineers

LOOP Loss of Offsite Power
NEI Nuclear Energy Institute
NRC U.S. Nuclear Regulatory Commission
RG Regulatory Guide
SDP Significance Determination Process
SFCP Surveillance Frequency Control Program
SSC Structure, System, or Component

STI Surveillance Test Interval

UFSAR Updated Final Safety Analysis Report
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