IR 05000454/2017009

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
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:	ML17355A561 (21 December 2017)
Download: ML18313A121 (13)

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

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