ML25126A101
| ML25126A101 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  (NPF-072) |
| Issue date: | 05/05/2025 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Seawright B Constellation Energy Generation, Constellation Nuclear |
| Wall, S | |
| References | |
| EPID L-2025-LLR-0049 | |
| Download: ML25126A101 (1) | |
Text
From:
Scott Wall To:
Seawright, Brian: (Constellation Nuclear)
Cc:
Steinman, Rebecca L:(Constellation Nuclear)
Subject:
FINAL RAI - Braidwood, Unit 1 - Relief Request RR-4 (Auxiliary Feedwater Air Operated Flow Control Valves)
Date:
Monday, May 5, 2025 11:22:23 AM
Dear Brian Seawright,
By a letter dated April 28, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25118A331), Constellation Energy, LLC (the licensee) submitted Alternative Request RR-4 to the U.S. Nuclear Regulatory Commission (NRC) regarding certain inservice testing (IST) requirements of the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the IST Program at Braidwood Station (Braidwood), Unit 1, for the Fourth IST Program Interval.
The NRC staff has reviewed the submittal and determined that additional information is needed to complete its review. The specific question is found in the enclosed request for additional information (RAI). On May 5, 2025, the CEG staff indicated that a response to the RAIs would be provided by May 9, 2025.
If you have questions, please contact me at 301-415-2855 or via e mail at Scott.Wall@nrc.gov.
Scott P. Wall Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301.415.2855 Scott.Wall@nrc.gov Docket No.: STN 50-456
Enclosure:
Request for Additional Information cc: Listserv RAI (Alternative Request RR-4)
REQUEST FOR ADDITIONAL INFORMATION ALTERNATIVE REQUEST RR-4 POST-MAINTENANCE TESTING OF AIR-OPERATED CONTROL VALVE FOURTH INSERVICE TESTING PROGRAM INTERVAL CONSTELLATION ENERGY GENERATION, LLC BRAIDWOOD STATION, UNIT 1
DOCKETNO.STN50456
By a letter dated April 28, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25118A331), Constellation Energy, LLC (the licensee) submitted Alternative Request RR-4 to the U.S. Nuclear Regulatory Commission (NRC) regarding certain inservice testing (IST) requirements of the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the IST Program at Braidwood Station (Braidwood), Unit 1, for the Fourth IST Program Interval.
Specifically, the licensee requested a one-time alternative to the post-maintenance testing requirements in the ASME OM Code as incorporated by reference in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, Codes and standards, for the Auxiliary Feedwater (AF) air-operated flow control valve 1AF005F at Braidwood Unit 1 on the basis that the alternative provides acceptable level of quality and safety under 10 CFR 50.55a(z)
(1). The licensees submittal requests a one-time allowance to IST Program testing to perform a partial stroke test in lieu of the OM Code required full-stroke exercise following maintenance to repair to the 1AF005F valve.
The U.S. Nuclear Regulatory Commission (NRC) staff determined that the following information is needed to complete its review.
Mechanical Engineering & Inservice Testing Branch (EMIB) Request for Additional Information (RAI)
EMIB-RAI-1:
Regulatory Requirements:
The NRC regulations in 10 CFR 50.55a(z), Alternatives to codes and standards requirements, state the following:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Issue In Section 5.0, Proposed Alternative and Basis for Use, of Alternative Request RR-4, the licensee states that the proposed post-maintenance test will close the 1AF005F valve using the air operator and then ensure the valve is closed using the handwheel. The licensee then states that utilizing this test method, the handwheel may not move the obturator if the valve fully closes via the air operator.
Request Based on past experience where handwheel operation interfered with the air-operated function of the 1(2)AF005 valves at the Braidwood and Byron nuclear power plants, the licensee is requested to describe its plan to ensure that the air-operated function of the 1AF005F valve at Braidwood Unit 1 has not been degraded if it is necessary to use the handwheel to fully close the valve manually during the proposed post-maintenance test.