RS-22-123, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator

Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator

ML22342B230
Person / Time
Site:	Calvert Cliffs, Byron, Braidwood, Ginna
Issue date:	12/07/2022
From:	Lueshen K Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-22-123
Download: ML22342B230 (1)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-22-123 10 CFR 50.90 December 7, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections"

References:

1. Letter from K. Lueshen (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, "Application to Revise Technical Specifications to Adopt TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections'," dated August 10, 2022 (ADAMS Accession No. ML22222A068)

2. Email from J. Wiebe (U.S. Nuclear Regulatory Commission) to L. Simpson (Constellation Energy Generation), "Draft RAI for Adoption of TSTF-577,"

dated November 4, 2022 In Reference 1, Constellation Energy Generation, LLC (CEG) requested amendments to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood); Renewed Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron); Renewed Facility Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs); and Renewed Facility Operating License No. DPR-18 for R.E. Ginna Nuclear Power Plant (Ginna).

December 7, 2022 U.S. Nuclear Regulatory Commission Page 2 The proposed changes would revise the "Steam Generator (SG) Program" and the "Steam Generator Tube Inspection Report" Technical Specifications (TS) based on Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" (TSTF-577) (ML21060B434), and the associated NRC safety evaluation (SE) (ML21098A188).

In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) requested additional information that is needed to complete review of the proposed changes specific to Braidwood, Calvert Cliffs, and Ginna. Attachment 1 provides the additional information. The request for additional information is not applicable to Byron; however, Attachment 1 provides an administrative clarification regarding dates provided for Byron in Section 2.1 of Reference 1.

CEG has reviewed the information supporting the finding of no significant hazards consideration, and the environmental consideration that were previously provided to the NRC in Reference 1.

The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments included in this letter.

CEG is notifying the State of Illinois, the State of Maryland, and State of New York of this supplement to a previous application for a change to the operating license by sending a copy of this letter and its attachments to the designated Illinois, Maryland, and New York Officials in accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b).

If you should have any questions regarding this letter, please contact Ms. Lisa Simpson at (630) 657-2815.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7th day of December 2022.

Respectfully, Lueshen, Digitally signed by Lueshen, Kevin Kevin Date: 2022.12.07 15:09:45

-06'00' Kevin Lueshen Sr. Manager - Licensing Constellation Energy Generation, LLC

Attachment:

Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections"

December 7, 2022 U.S. Nuclear Regulatory Commission Page 3 cc: NRC Project Manager - NRR - Braidwood / Byron NRC Project Manager - NRR - Calvert Cliffs NRC Project Manager - NRR - Ginna NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRC Senior Resident Inspector, Calvert Cliffs NRC Senior Resident Inspector, Ginna Illinois Emergency Management Agency - Division of Nuclear Safety A. L. Peterson, NYSERDA S. Seaman, State of Maryland

ATTACHMENT 1 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" In letter dated August 10, 2022 (Reference 1), Constellation Energy Generation, LLC (CEG) requested amendments to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood); Renewed Facility Operating License Nos.

NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron); Renewed Facility Operating License Nos. DPR-53 and DPR-69 for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs); and Renewed Facility Operating License No. DPR-18 for R.E. Ginna Nuclear Power Plant (Ginna).

By email dated November 4, 2022 (Reference 2), the U.S. Nuclear Regulatory Commission (NRC) requested additional information to complete review of the proposed changes. This Attachment provides the additional information.

NRC REQUEST FOR ADDITIONAL INFORMATION Introduction By license amendment request (application) dated August 10, 2022 (Agencywide Documents Access and Management System Accession No. ML22222A068), Constellation Energy Generation, LLC (the licensee) requested changes to the technical specifications (TS) for Braidwood Station, Units 1 and 2 (Braidwood); Byron Station Units 1 and 2 (Byron); Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs); and R.E. Ginna Nuclear Power Plant (Ginna). Note that this request for additional information is not applicable to Byron. The licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the "Steam Generator (SG) Program" and the "Steam Generator Tube Inspection Report" TS based on Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, "Revised Frequencies for Steam Generator Tube Inspections" (TSTF-577) (ML21060B434), and the associated NRC staff safety evaluation (SE)

(ML21098A188).

The tubes within a steam generator (SG) function as an integral part of the reactor coolant pressure boundary and, in addition, isolate fission products in the primary coolant from the secondary coolant and the environment. SG tube integrity means that the tubes are capable of performing this safety function in accordance with the plant design and licensing basis.

The NRC staff has determined that additional information is needed to complete its review, as described below.

Regulatory Basis The regulation in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36(c)(5),

"Administrative Controls," states in part, that "Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." All pressurized water reactors have TS according to 10 CFR 50.36 that include a SG Program with specific criteria for the structural and leakage integrity, repair, and inspection of SG tubes. At Constellation, programs 1 of 5

ATTACHMENT 1 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" established by the licensee, including the SG Program, are listed in the administrative controls section of the TS to operate the facility in a safe manner.

Request for Additional Information To complete its evaluation of whether the proposed changes meet the SG Program requirements described above, the NRC staff requests the following information.

Traveler TSTF-577 in part, revises the standard technical specifications related to SG tube inspections to extend the inspection interval for thermally treated Alloy 600 (Alloy 600TT) and thermally treated Alloy 690 (Alloy 690TT) SG tubing. By letter dated August 10, 2022 (ML22222A068), the licensee applied to adopt TSTF-577 for Braidwood, Byron, Calvert Cliffs, and Ginna. According to TSTF-577, the new SG TS inspection period would start after a 100 percent inspection of all SG tubes performed during a single outage. In the application to adopt TSTF-577, Braidwood, Calvert Cliffs, and Ginna provided SG TS markups that reflect the new SG TS tube inspection provisions however, these units have not yet completed, or do not credit completion of, the required inspection. As described in the application, these units plan to complete the required inspection in future outages, after the adoption of TSTF-577. To address this situation (i.e., adopting TSTF-577 prior to completing the required inspection) the licensee proposed a license condition. The license condition would restrict the use of the extended inspection interval until after completion of the 100% inspection of all tubes in a single outage.

In general, the proposed license condition for each applicable unit states, "[t]he extended inspection interval of TS 5.5.9 will not be permitted following implementation of the TSTF-577 amendment until after performance of a 100% inspection of all tubes in a single outage." Based on the preceding information, the NRC staff requests additional information to better understand the proposed approach.

1. The application described plans to complete the required inspection in future outages, after the adoption of TSTF-577. Upon implementing the amendment, which allows an extended inspection interval, each applicable units proposed license condition specifies that the extended inspection interval of TS 5.5.9 (typical) will not be permitted until after performance of the required inspection (emphasis added). However, it does not state the inspection requirements that will be in effect and how they are controlled before performance of the required inspection (emphasis added). Based on the approach described in the application and summarized above, the NRC staff requests that the licensee describe what inspection requirements and interval will be in effect and how they are controlled prior to the performance of a 100% inspection of all SG tubes in a single outage and implementation of TSTF-577. As part of the response, explain how the proposed approach supports the TS administrative controls necessary to assure operation of the facility in a safe manner.

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ATTACHMENT 1 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" CEG Response to RAI The CEG application dated August 10, 2022 (Agencywide Documents Access and Management System Accession No. ML22222A068) (Reference 1) described plans to complete the required inspection in future outages, after the adoption of TSTF-577. However, as discussed during the NRC clarification call on November 9, 2022, CEG now intends to credit a 100% SG tube inspection performed during a single refueling outage for each unit prior to approval of the amendments; consequently, no change to inspection requirements and/or intervals is required to be in effect prior to the performance of a 100% inspection of all SG tubes in a single outage and implementation of TSTF-577. Furthermore, there will be no need for additional or different TS administrative controls to assure operation of the facilities in a safe manner. Once the amendments for Braidwood, Units 1 and 2, Calvert Cliffs, Units 1 and 2, and Ginna are approved, the TS will be implemented within 120 days.

As some of the outages to complete the 100% SG tube inspections have not yet transpired, CEG intends to submit a supplement following the completion of the inspections described in the SG Program for the Braidwood Unit 2 spring refueling outage (A2R23) and the Ginna spring refueling outage (G1R44) planned for submittal in May 2023. The May 2023 supplement will also eliminate the proposed license conditions from Reference 1 for Braidwood, Calvert Cliffs, and Ginna as they will no longer be applicable.

The specific details for each applicable unit of Reference 1 are provided below.

Braidwood, Unit 1:

The initial inspection period described in the SG Program, paragraph d.2, began October 18, 2022, for Braidwood, Unit 1. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

Braidwood, Unit 2:

The initial inspection period described in the SG Program, paragraph d.3, is scheduled to begin in spring 2023 for Braidwood, Unit 2. The May 2023 supplement will provide the date of the 100% SG tube inspection performed during the A2R23 spring 2023 refueling outage (i.e., date of entering MODE 4 at the end of the refueling outage). CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

Calvert Cliffs, Unit 1*:

The initial inspection period described in the SG Program, paragraph d.2, began March 9, 2020, for Calvert Cliffs, Unit 1. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

Calvert Cliffs, Unit 2*:

The initial inspection period described in the SG Program, paragraph d.2, began March 14, 2019, for Calvert Cliffs, Unit 2. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 60 days after implementation of the license amendment.

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ATTACHMENT 1 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections"

• Note: For Calvert Cliffs, Units 1 and 2, the dates provided in Reference 1 credited future outages in 2026 and 2025, respectively. In this letter, Calvert Cliffs, Units 1 and 2, credit a 100% SG tube inspection performed during a single refueling outage for each unit prior to approval of the amendments.

Ginna:

The initial inspection period described in the SG Program, paragraph d.2, is scheduled to begin in spring 2023 for Ginna. The May 2023 supplement will provide the date of the 100% SG tube inspection performed during the G1R44 spring 2023 refueling outage (i.e., date of entering MODE 4 at the end of the refueling outage). CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.7 requirements within 60 days after implementation of the license amendment.

Variation As discussed during the NRC clarification call on November 9, 2022, one additional Variation is added to the Variations from Reference 1:

Reference 1 included a time period for when CEG would submit a SG Tube Inspection Report meeting the revised TS requirements (i.e., within 30 days after implementation of the license amendment). This time period, based on the TSTF-577 Model Application, will be extended such that CEG will submit SG Tube Inspection Reports meeting the revised Braidwood TS 5.6.9, Calvert Cliffs TS 5.6.9, and Ginna TS 5.6.7 requirements within 60 days after implementation of the license amendments. This extension from 30 to 60 days is to allow for a staggered implementation for these CEG units. This difference from the TSTF-577 Model Application is administrative and does not affect the applicability of TSTF-577 to the Braidwood, Calvert Cliffs, and Ginna TS.

Administrative Clarification - Byron Dates As part of the review of information provided in CEG application dated August 10, 2022 (Reference 1), it was identified that the dates provided of the 100% SG tube inspections performed during Byron, Units 1 and 2, prior to approval of the amendments were inaccurate.

Based on a consistent CEG fleet approach of using the date for entry into MODE 4 at the end of the refueling outage, the dates are corrected and are applicable for Byron, Units 1 and 2, in the following paragraph from Section 2.1 of Reference 1:

Byron, Units 1 and 2:

The initial inspection period described in the SG Program, paragraph d.2, began March 24, 2020, for Byron, Unit 1, and the initial inspection period described in the SG Program, paragraph d.3, began May 10, 2022, for Byron Unit 2. CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 30 days after implementation of the license amendment at Byron.

Note: As the request for additional information (Reference 2) is not applicable to Byron, the additional Variation included above will not apply to Byron, Units 1 and 2 (i.e., CEG will submit a SG Tube Inspection Report meeting the revised TS 5.6.9 requirements within 30 days after implementation of the license amendment at Byron, as stated in Reference 1).

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ATTACHMENT 1 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, "Revised Frequencies for Steam Generator Tube Inspections" REFERENCES

1. Letter from K. Lueshen (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, "Application to Revise Technical Specifications to Adopt TSTF-577, 'Revised Frequencies for Steam Generator Tube Inspections'," dated August 10, 2022 (ADAMS Accession No. ML22222A068)

2. Email from J. Wiebe (U.S. Nuclear Regulatory Commission) to L. Simpson (Constellation Energy Generation), "Draft RAI for Adoption of TSTF-577," dated November 4, 2022 5 of 5