ML23321A044
| ML23321A044 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/17/2023 |
| From: | Gugle G Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML23321A043 | List: |
| References | |
| BW230054 | |
| Download: ML23321A044 (1) | |
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November 17, 2023 BW230054 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Braidwood Station, Unit 2 Renewed Facility Operating License No. NFP-77 NRC Docket No. STN 50-457 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" In accordance with Appendix B, Section 8.1.c of Nuclear Energy Institute (NEI) 03-08, "Guideline for the Management of Materials Issues," Revision 4, Constellation Energy Generation, LLC (CEG) is notifying the U.S. Nuclear Regulatory Commission (NRC) that Braidwood Station, Unit 2 has processed a deviation from a "Needed" requirement in EPRI Document MRP 227, Revision 1-A, "Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guideline," with appropriate justification and documentation.
MRP-227, Revision 1-A, Table 4-3, Item W6: "Baffle-Former Assembly; Baffle-Former Bolts" requires that Tier 4 plants perform baseline volumetric examinations of Baffle-Former Bolts no later than 35 effective full power years (EFPY), as stated in Table 4-3, Note 8. Based on the schedule of the reactor vessel internals examination for Braidwood Unit 2, the plant will exceed the EFPY requirement for performing these baseline examinations. Per the implementation requirements under Subsection 7.3 of MRP-227, Revision 1-A, there is a NEI 03-08 "Needed" requirement which states, "each commercial U.S. PWR unit shall implement the requirements of Tables 4-1 through 4-9 and Tables 5-1 through 5-3 for the applicable design".
Per NEI 03-08, "Needed" requirements or guidance are "to be implemented whenever possible but alternative approaches are acceptable". The deviation has been documented in accordance with CEG's corrective action program and approved by the appropriate levels of CEG management.
Attachments 1 and 2 provide the deviation form and the technical justification, respectively.
In accordance with NEI 03-08, this letter is being transmitted for information only. CEG is not requesting any action from the NRC.
November 17, 2023 U.S. Nuclear Regulatory Commission Page 2 This letter contains no new regulatory commitments.
Please direct any questions you may have regarding this letter to Mr. Dane Brunswick, Regulatory Assurance Manager, at (815) 417-2800.
Respectfully,
- Gugle, Greg Digitally signed by Gugle, Greg Date: 2023.11.16 06:03:13 -06'00' Gregory Gugle Site Vice President Braidwood Station : ER-AA-4003 Attachment 2 - NEI 03-08 Deviation Form for Baffle-Former Bolts Volumetric Examination for Byron Units 1 and 2 and Braidwood Unit 2 : EC 639996 (Byron), Revision 1 and 640160 (Braidwood), Revision 0, Technical Evaluation for NEI 03-08 Deviation of Baffle-Former Bolts Volumetric Examinations for Byron and Braidwood cc:
NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Project Manager, NRR - Braidwood and Byron Stations Illinois Emergency Management Agency - Division of Nuclear Safety