ML24094A270

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MDMP Deviation Form
ML24094A270
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 04/03/2024
From: Cruz O
Constellation Energy Generation
To:
Office of Nuclear Reactor Regulation
Shared Package
ML24094A268 List:
References
BW240017 ER-AA-4003, Rev 6
Download: ML24094A270 (1)


Text

ER-AA-4003 Revision 6 ATTACHMENT 2 MDMP Deviation Form Page 1 of 2

Utility: Constellation Energy Generation (CEG), LLC

Applicable Site(s) and Unit No.: Braidwood Units 1 and 2

Utility Contact(s):

Osvaldo Cruz - Fleet PWR Internals Program Engineer, Osvaldo.Cruz@constellation.com Kemper Young - Fleet PWR Internals Program Engineer, Kemper.Young@constellation.com

Issue Program (IP) activity or document:

PWROG Report, WCAP-17451-P, Revision 2, Reactor Internals Guide Tube Wear - Westinghouse Domestic Fleet Operational Projections, November 2018.

Scope / Description of Deviation:

CEG is submitting this NEI 03-08 deviation for Braidwood Units 1 and 2 to perform the baseline Control Rod Guide Tube (CRGT) Guide Card Wear Measurements (GCWM) no later than the A1R30 (Spring 2033) and A2R30 (Fall 2033) Refueling Outages (RFO).

The Nuclear Energy Institute (NEI) 03-08 Needed requirements are identified in WCAP-17451-P Revision 2, Section 6.0. As such, WCAP-17451-P, Revision 2, Table 5-14 and Section 5.4 specify that the baseline CRGT GCWM for Braidwood Units 1 and 2 should take place prior to 32.8 and 33.5 Effective Full Power Years (EFPY), respectively. Per NEI 03-08, Needed requirements or guidance are to be implemented whenever possible but alternative approaches are acceptable. Technical justification has been developed under EC 640658 to deviate from the Needed requirement in WCAP-17451-P Revision 2, Section 6.0 because it will not be implemented within the timeframe specified therein.

Reason for Deviation:

This deviation is being submitted to defer the baseline CRGT GCWM for six additional RFOs in order to provide the station with a more favorable business case and outage planning and execution with no reduction in quality and safety.

IR Number: 04739313 EC Number: 640658

Time Frame the Deviation will be in Effect:

The deviation will be in effect until no later than the completion of the following outages for Braidwood Units 1 and 2:

Plant Outage Projected EFPY Braidwood Unit 1 A1R30 (Spring 2033) 40.9 Braidwood Unit 2 A2R30 (Fall 2033) 41.7

Deviation to this IP document is classified as: NEEDED