ML100430318

Regulatory Commitment Change Summary Report

ML100430318
Person / Time
Site:	Braidwood
Issue date:	02/05/2010
From:	Shahkarami A Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BW100016
Download: ML100430318 (5)

Text

February 05,2010 BW100016 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 5Q..457

Subject:

RegUlatory Commitment Change Summary Report Enclosed is the Exelon Generation Company, LLC (EGC) "Regulatory Commitment Change Summary Report" for Braidwood Station. This report includes a summary of the changes processed during the period from January 1, 2009 through December 31, 2009. Note that a summary of changes associated with Commitment Change Tracking Numbers 2009-01 and 2009-02 is not included in the attached since these changes were determined not to meet the criteria for inclusion in the annual Commitment Change Summary Report. Revisions to regulatory commitments were processed in accordance with Nuclear Energy Institute's (NEI) 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes," dated July 1999 and applicable procedures.

Should you have any questions concerning this report, please contact Mr. David Gullott, Regulatory Assurance Manager, at (815) 417-2800.

Respectfully, Site Vice President Braidwood Station

Attachment:

Regulatory Commitment Change Summary Report cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector - Braidwood Station

Attachment Braidwood Station Regulatory Commitment Change Summary Report Commitment Change Tracking Number: 2009-03 Originating Document:

NRC Safety Evaluation associated with Braidwood Technical Specification (TS) Amendment No.

60, issued on February 28, 1995.

Subject of Change:

Delete the original commitment to perform periodic 3-year chlorine survey.

Original Commitment:

The NRC Safety Evaluation for Braidwood TS Amendment No. 60, issued on February 28, 1995 requires that a chlorine survey and associated evaluations be performed every 3 years to ensure the risk to control room personnel from any potential chlorine accident is maintained sufficiently small. The results of the survey and analysis shall be documented in the Station annual reports.

The commitment to perform a chemical survey every 3 years was made in support of a license amendment request to eliminate periodic testing of the Control Room Ventilation System in the isolation mode (i.e., TS Surveillance Requirement 4.7.6.e.6). The basis for eliminating testing in the isolation mode was a new evaluation and survey that demonstrated that the chlorine hazard had become practically zero with the removal of the Norfolk and Western railway.

Revised Commitment:

Delete the original commitment to perform periodic 3-year chlorine survey based on implementation of Braidwood TS Amendment No. 146, "Control Room Habitability," issued on October 31, 2007 (With correction letter issued on December 7, 2007). Chlorine transportation and storage will continue to be surveyed and evaluated as part of the periodic chemical surveys required by TS 5.5.18, "Control Room Envelope Habitability Program," implemented as a result of TS Amendment No. 146.

Basis:

The commitment to perform periodic chlorine surveys and evaluations is no longer required since implementation of TS Amendment No. 146 requires performance of periodic chemical surveys and evaluations, which includes chlorine. The commitment associated with TS Amendment No. 60 only encompassed a single chemical, i.e., chlorine, and past performance of the surveys did not identify any probabilistic chlorine hazards.

The chlorine survey performed in support of TS Amendment No. 60 was performed on a 3-year frequency. The chemical survey performed as required by TS Amendment No. 146 is performed on a 6-year frequency. The frequency is based on RegUlatory Guide (RG) 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision O. TS 5.5.18 also requires determining the unfiltered air inleakage past the Control Room Envelope (CRE) boundary into the CRE in accordance with the test methods and frequencies specified in Sections C.1 and C.2 of RG 1.197, Revision O. The unfiltered air inleakage test is performed on a 6-year frequency. TS 5.5.18 Page 1 of 4

Attachment Braidwood Station Regulatory Commitment Change Summary Report requires that the chemical evaluation and the unfiltered air inleakage test be staggered such that performance of either occurs every 3 years in accordance with the frequencies specified in RG 1.197, Revision O.

The commitment is no longer required since TS 5.5.18 imposes requirements for performing a chemical evaluation at frequencies consistent with Sections C.1 and C.2 of RG 1.197. TS Amendment No. 146 is a result of the adoption of Technical Specification Task Force (TSTF)

Traveler, TSTF-448, "Control Room Habitability." As stated in the NRC safety evaluation associated with TS Amendment No. 146, "the changes made by TSTF-448 to the STS requirements for the VC Filtration System and the CRE boundary conform to 10 CFR 50.36(d)(2) and 10 CFR 50.36(d)(3). Their adoption will better assure that the Braidwood CRE will remain habitable during normal operation and design DBAs."

Page 2 of 4

Attachment Braidwood Station Regulatory Commitment Change Summary Report Commitment Change Tracking Number: 2009-04 Originating Document:

Letterfrom T.J. Tulon to U.S. NRC, "Reply to Notice of Violation," dated February 27, 1998.

Subject of Change:

Delete the original commitment to monitor the Cathodic Protection (GD) System via system specific performance criteria.

Original Commitment:

Braidwood Station received a violation for failing to establish adequate measures to evaluate the effectiveness of the performance of appropriate preventive maintenance on the GD System prior to placing it under Maintenance Rule 10 CFR 50.65 section (a)(2). Maintenance Rule 10 CFR 50.65 section (a)(2) classification is for equipment that is being effectively controlled through the performance of appropriate preventive maintenance such that the system or component remains capable of performing its intended function. The violation was based on the use of plant level monitoring criteria to disposition the GD System as 10 CFR 50.65 section (a)(2) as opposed to having specific performance criteria. The violation indicated that plant level performance measures would allow excessive failures because failures offunction GD-01 (Le., protect underground systems, structures, and components from corroding) would not consistently affect the performance measures. The Notice of Violation was transmitted in a letter from J.A. Grobe (U.S.

NRC) to 0.0. Kingsley (Commonwealth Edison Company), "NRC Inspection Report 50-456/97018 (DRS); 50-457/97018 (DRS) and Notice of Violation," dated January 30, 1998.

In the Reply to Notice of Violation, dated February 27, 1998, the following commitment was made:

"New performance criteria for the Cathodic Protection (GD) system will be developed and submitted to the Maintenance Rule Expert Panel for approval."

The response indicated that full compliance would be achieved by April 15, 1998 when the specified performance criteria changes are to be approved and in place.

Revised Commitment:

Delete the original commitment to monitor the GD System via system specific performance criteria based on the removal of function GO-01 from the scope of the Maintenance Rule.

Basis:

A violation was issued for failing to establish adequate performance criteria to monitor in-scope function GD-01. Due to function GD-01 being considered non risk-significant by the Maintenance Rule Expert Panel, monitoring of the function was established utiliZing the plant level criteria rather than developing and utilizing system specific performance criteria. During the NRC Baseline Inspection conducted in December of 1997, the appropriateness of the established monitoring was Page 3 of 4

Attachment Braidwood Station Regulatory Commitment Change Summary Report challenged because plant level monitoring would allow excessive failures that would not necessarily be captured by the plant level criteria.

Based on subsequent review, the Maintenance Rule Expert Panel concurred that plant level monitoring was inappropriate. In the Reply to Notice of Violation, a commitment was made to develop specific performance criteria to monitor in-scope function GD-01. System specific performance criteria was approved by the Expert Panel in March 1998; thus, satisfying the commitment (I.e., Performance Criterion GD~01).

Following completion of the Maintenance Rule Baseline Inspections, a commonality effort was initiated to standardize the Maintenance Rule monitoring being performed across the fleet. The intent of the effort was to standardize performance criteria for systems that are common to all of the sites (e.g., Cathodic Protection, Switchyard, etc.). As a result, it was determined that function GD-01 did not require inclusion within the scope of the Maintenance Rule based on not satisfying any of the scoping criteria defined in Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," or NUMARC 93-01, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Consequently, in June of 1999, the Maintenance Rule Expert Panel, based on fleet as well as industry input, approved the removal of function GD~01 from the scope of the Maintenance Rule resulting in the GD System specific performance criteria that was preViously developed no longer being required. As a result, the performance criteria was retired.

Initial inclusion of function GD-01 within the scope of the Maintenance Rule required the establishment of appropriate performance criteria. The violation issued following the Baseline Inspection was due to an in-scope function not having appropriate performance criteria established.

Subsequently, function GD~01 was removed from the scope of the Maintenance Rule and the specific performance criteria is no longer required.

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