ML110350434

Regulatory Commitment Change Summary Report

ML110350434
Person / Time
Site:	Braidwood
Issue date:	02/04/2011
From:	Shahkarami A Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BW110009
Download: ML110350434 (2)

Text

February 04, 2011 BW110009 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 50-457

Subject:

Regulatory Commitment Change Summary Report Enclosed is the Exelon Generation Company, LLC (EGG) "Regulatory Commitment Change Summary Report" for Braidwood Station. This report includes a summary of a commitment change processed during the period from January 1, 2010 through December 31,2010. This change was found 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. Ronald Gaston, Regulatory Assurance Manager, at (815) 417-2800.

Respectfully, Am" Shahkaralf Site Vice President Braidwood Station f

Attachment:

Regulatory Commitment Change Summary Report cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector - Braidwood Station Illinois Emergency Management Agency - Division of Nuclear Safety Illinois Emergency Management Agency - Braidwood Representative

Attachment Braidwood Station Regulatory Commitment Change Summary Report Commitment Change Tracking Number: 2008-03 Originating Document:

NUREG-1002, "Safety Evaluation Report related to the operation of Braidwood Station, Units 1 and 2," Supplement 1, dated September 1986.

Subject of Change:

Delete the original commitment to maintain the hydrogen recombiner discharge valves (00G060 and 00G066) de-energized in the open position.

Original Commitment:

As stated in Section 6.2.5, "Combustible Gas Control System," of NUREG-1002, Supplement 1:

"The applicant's hydrogen recombiner system design eliminates the potential for backflow as discussed above, and is, therefore, an improvement on the design described in the SER. That is, however, contingent on the recombiner discharge valves being kept open during normal operation; the applicant must ensure that appropriate administrative controls are instituted to maintain the discharge valves open. The applicant has committed to satisfy this requirement."

Revised Commitment:

Delete the original commitment to maintain the hydrogen recombiner discharge valves de-energized in the open position based on implementation of Braidwood Technical Specification (TS)

Amendment No. 137, "Hydrogen Recombiners and Hydrogen Monitors," issued on May 26,2005, and subsequent abandonment of the hydrogen recombiner system.

Basis:

Approval of Braidwood TS Amendment No. 137 revised the licensing basis associated with combustible gas control systems by removing the design-basis Loss of Coolant Accident (LOCA) hydrogen release from the licensing basis for Braidwood Station. The Commission found that hydrogen release is not risk-significant because the design-basis LOCA hydrogen release does not contribute to the conditional probability of a large release up to approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the onset of core damage. In addition, the NRC found that these systems were ineffective at mitigating hydrogen releases from risk-significant beyond design-basis accidents. Therefore, the Commission eliminated the hydrogen release associated with a design-basis LOCA from 10 CFR 50.44 and the associated requirements that necessitated the need for the hydrogen recombiners and the backup hydrogen vent and purge systems. As a result, the requirements related to hydrogen recombiners no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TSs and were eliminated from TSs via Braidwood TS Amendment No. 137.

The hydrogen recombiner system was subsequently abandoned in place utilizing the interim abandonment process.

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