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Category:Letter
MONTHYEARIR 05000456/20230042024-02-0202 February 2024 Integrated Inspection Report 05000456/2023004 and 05000457/2023004 IR 05000454/20230042024-02-0202 February 2024 Integrated Inspection Report 05000454/2023004 and 05000455/2023004 ML24025C7242024-01-29029 January 2024 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000456/2024002; 05000457/2024002 IR 05000457/20230112024-01-25025 January 2024 2B Auxiliary Feedwater Pump Diesel Fuel Oil Dilution Report 05000457/2023011 and Preliminary Greater than Green Finding and Apparent Violation ML24022A2722024-01-23023 January 2024 Request for Information for an NRC Post-Approval Site Inspection for License Renewal Inspection Report 05000454/2024011 ML24018A0362024-01-17017 January 2024 Paragon Energy Solutions, Defect with Detroit Diesel/Mtu Fuel Injectors P/N R5229660 Cat Id 0001390618 RS-24-004, Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators2024-01-11011 January 2024 Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators ML23348A2162023-12-15015 December 2023 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0030 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000456/20200232023-12-15015 December 2023 Baseline Security Inspection Document; 05000456/2023/402; 05000457/2023/402 ML23320A1762023-12-13013 December 2023 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0027 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23277A0032023-12-11011 December 2023 Issuance of Amendments Regarding Adoption of TSTF-370 ML23339A0452023-12-0505 December 2023 Request for Information for an NRC Post-Approval Site Inspection for License Renewal Inspection Report 05000546/2024010 ML23313A1552023-12-0101 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report ML23318A5102023-12-0101 December 2023 Relief from the Requirements of the ASME Code IR 05000454/20233012023-11-27027 November 2023 NRC Initial License Examination Report 05000454/2023301 and 05000455/2023301 ML23331A8922023-11-22022 November 2023 Supplement - Braidwood Security Rule Exemption Request ISFSI Docket No. Reference 05000457/LER-2023-001, Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case2023-11-17017 November 2023 Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case ML23321A0442023-11-17017 November 2023 Notification of Deviation from Electric Power Research Institute (EPRI) Topical Report MRP-227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guideline BYRON 2023-0065, Unit 2 - Notification of Deviation from Electric Power Research Institute (EPRI) Topical Report MRP-227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guideline2023-11-17017 November 2023 Unit 2 - Notification of Deviation from Electric Power Research Institute (EPRI) Topical Report MRP-227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guideline BYRON 2023-0063, Day Inservice Inspection Report for Interval 4, Period 3, (B2R24)2023-11-16016 November 2023 Day Inservice Inspection Report for Interval 4, Period 3, (B2R24) IR 05000454/20230032023-11-13013 November 2023 Integrated Inspection Report 05000454/2023003 and 05000455/2023003 and Exercise of Enforcement Discretion RS-23-117, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums RS-23-118, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML23313A0852023-11-0909 November 2023 Submittal of 2023-301 Byron Initial License Examination Post-Examination Comments RS-23-114, Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds2023-11-0101 November 2023 Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds ML23297A2352023-10-26026 October 2023 Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection IR 05000456/20234012023-10-18018 October 2023 Security Baseline Inspection Report 05000456/2023401 and 05000457/2023401 IR 05000456/20230102023-10-18018 October 2023 Functional Engineering Inspection Commercial Grade Dedication Report 05000456/2023010 and 05000457/2023010 RS-23-100, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-10-13013 October 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans RS-23-108, Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles2023-10-11011 October 2023 Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles RS-23-105, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections2023-10-10010 October 2023 Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections ML23278A0272023-10-0505 October 2023 Operator Licensing Examination Approval - Byron Station, October 2023 RS-23-094, Relief Request I4R-24, Alternative for Post-Peening Reexamination Frequency for Reactor Pressure Vessel Head Penetration Nozzle Number 752023-09-29029 September 2023 Relief Request I4R-24, Alternative for Post-Peening Reexamination Frequency for Reactor Pressure Vessel Head Penetration Nozzle Number 75 RS-23-093, License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel.2023-09-29029 September 2023 License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel. ML23251A1622023-09-29029 September 2023 Steam Generator Tube Inspection Reports to Reflect TSTF-577 Reporting Requirements RS-23-091, Relief Request I4R-25, Alternative Requirements for Reactor Pressure Vessel Inservice Inspection Intervals2023-09-26026 September 2023 Relief Request I4R-25, Alternative Requirements for Reactor Pressure Vessel Inservice Inspection Intervals ML23226A0062023-09-19019 September 2023 Review of License Renewal Commitment Number 10 Submittal ML23180A1692023-09-11011 September 2023 Calvert Cliff Units 1 & 2, and R.E. Ginna Plant - Withdrawal of Proposed Alternatives to American Society of Mechanical Engineers (ASME) Requirements (Epids L-2022-LRR-0074, 0076, 0079, 0091, 0092, 0093 and 0094) ML23242A3282023-09-0101 September 2023 Amendment No. 233 Correction IR 05000454/20235012023-08-31031 August 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000454/2023501 and 05000455/2023501 IR 05000454/20230052023-08-30030 August 2023 Updated Inspection Plan for Byron Station (Report 05000454/2023005 and 05000455/2023005) IR 05000456/20230052023-08-30030 August 2023 Updated Inspection Plan for Braidwood Station Report 05000456/2023005 and 05000457/2023005 ML23234A2462023-08-25025 August 2023 Confirmation of Initial License Examination IR 05000456/20230022023-08-0303 August 2023 Integrated Inspection Report 05000456/2023002 and 05000457/2023002 IR 05000454/20230022023-08-0303 August 2023 Integrated Inspection Report 05000454/2023002 and 05000455/2023002 2024-02-02
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 27, 2015 Mr. Mark E. Kanavos Site Vice President Braidwood Station 35100 S. Rt. 53, Suite 84 Braceville, IL 60407
SUBJECT:
BYRON STATION, UNIT NOS. 1 AND 2, AND BRAIDWOOD STATION, UNITS 1AND2-RESPONSE TO LETTER DATED MARCH 4, 2014 (TAC NOS.
MF3591, MF3592, MF3593 AND MF3594)
Dear Mr. Kanavos:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated March 4, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14066A479), you asked the NRC to either (1) affirm the stated position in Attachment 1 of your March 4, 2014, letter or (2) describe why the stated position is not consistent with the Braidwood and Byron Stations current licensing bases for a natural circulation cooldown event.
The NRC staff reviewed your letter and determined that consideration of your request is more appropriately performed in accordance with the criteria in NRC staff inspection procedures. A determination of whether or not the natural circulation cooldown event will be included in an inspection will be made in accordance with NRC Inspection Manual Chapter 0305, "Operating Reactor Assessment Program" (ADAMS Accession No. ML14198A117). The specific activities and equipment included in the inspection scope are determined in accordance with the criteria in the specific inspection procedures. The reasons for considering your request in this manner are explained below.
By letter to Commonwealth Edison Company, the former licensee of Braidwood Nuclear Station, dated October 9, 1996 (ADAMS Accession No. ML15076A081), the NRC required information in accordance with Title 1O of the Code of Federal Regulations (1 O CFR), Section 50.54(f),
informatioR that could be used to verify compliance with the terms and conditions of licenses and NRC regulations, and that the plant updated final safety analysis reports properly describe the facilities, as well as to determine if other inspection activities or enforcement actions should be taken. The required information included the licensee's rationale for concluding that system, structure, and component configuration and performance are consistent with the design basis.
The stated position and supporting information in Attachment 1 of your March 4, 2014, letter is similar to the information required by the NRC's October 9, 1996, letter.
In its letter, the NRC stated:
It is emphasized that the NRC's position has been, and continues to be, that it is the responsibility of individual licensees to know their licensing basis, to have appropriate documentation that defines their design bases, and to have procedures for performing the necessary assessments of plant or procedure changes required by NRC regulations.
M. Kanavos The NRC's activities to confirm the information required by its October 9, 1996, letter is identified as design bases inspections. Similarly, the requested action in your March 4, 2014, letter is consistent with activities conducted during a Component Design Bases Inspection (CDBI). For example, the CDBI procedure (ADAMS Accession No. ML133318444), Section 02.02 a 2, instructs the inspector to verify that the licensing bases have not been degraded through modifications. To do this, the inspector needs to determine the current licensing bases.
The inspection procedure for Evaluation of Changes, Tests, and Experiments and Permanent Plant Modifications (ADAMS Accession No. ML101340791) has similar guidance.
The activities described above are most appropriately carried out at the plant where the inspectors have access to the plant, licensee documents, and licensee personnel. The interface between the inspector and licensee personnel and the accessibility of equipment and licensee documents during the inspection process facilitates thorough understanding of the equipment capability and design and licensing information. When unresolvable questions arise during inspection activities, the questions may be referred to NRC staff in the Office of Nuclear Reactor Regulation (NRR). The questions may be addressed and resolved informally or formally through the NRC Task Interface Agreement (TIA) process (ADAMS Accession No. ML13300A002). The above processes are well developed and understood. The processes support the ability to develop an informed determination about licensing bases that are often complex and located in historical licensing records. Responding to your request outside of these processes has the potential to result in an incomplete answer.
In your letter you included quotations from NRC staff safety evaluation reports. NRC safety evaluations (SEs) document NRC staff analysis and provide the regulatory bases for NRC decisions in licensing actions such as amendments, exemptions and relief requests and should not be used to attempt to establish licensing bases. The SEs may stress the importance of certain licensing bases information and can cite regulations, regulatory commitments, or other established licensing bases information. It is important to recognize that licensees provide the licensing bases information in their submittals so that there is no confusion following the licensing action.
It is important to note that 10 CFR provides the foundation for the licensing basis. A condition of the issued license is compliance with the regulations in 10 CFR. Without an exemption specifically approved by the NRC staff, the licensing basis includes compliance with 10 CFR regulations. The NRC staff provides guidance through the Standard Review Plan, Regulatory Guides, and other documents regarding methods to comply with 10 CFR that are acceptable to the staff. Deviations from this guidance are to be specifically pointed out and evaluated as to why they are acceptable alternatives by licensees in their licensing basis submittals.
M. Kanavos If you have any questions regarding this matter, I can be reached at 301-415-6606 or via e-mail at joel.weibe@nrc.gov.
Sincerely, c)-LV~
~oel S. Wiebe, Senior Project Manager Plant Licensing 111-2 and Planning and Analysis Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454 and STN 50-455 cc: Distribution via Listserv
ML15076A568 *via-email OFFICE LPL3-2/PM LPL3-2/LA OGC NLO RGNlll* LPL3-2/BC LPL3-2/PM NAME JWiebe SRohrer BMizuno EDuncan TT ate JWiebe DATE 4/27/15 4/28/15 4/3/15 3/30/15 4/30/15 5/27/15