RS-25-138, Application for Amendment to Renewed Facility License to Revise License Conditions 2.C(13)(b)(1) and 2.C(13)(b)(2)
| ML25276A085 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/03/2025 |
| From: | Steinman R Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-25-138 | |
| Download: ML25276A085 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-25-138 October 3, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Braidwood Station, Unit 1 Renewed Facility Operating License No. NPF-72 NRC Docket No. STN 50-456 Application for Amendment to Renewed Facility License to Revise License Conditions 2.C(13)(b)(1) and 2.C(13)(b)(2)
Reference:
NUREG-2190, "Safety Evaluation Report Related to the License Renewal of Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, Volume 2," dated December 2015 (ADAMS Accession No. ML15350A041)
In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Renewed Facility Operating License (RFOL) No. NPF-72 for Braidwood Station, Unit 1 (Braidwood). The proposed change revises license conditions 2.C(13)(b)(1) and 2.C(13)(b)(2) to extend the completion date of License Renewal Commitment 30 Enhancements 2 and 3 to October 16, 2026. These commitments, which are listed in Appendix A of the Reference, are related to ASME Section XI, Subsection IWL program enhancements and inspections of containment tendons that are currently required to be completed no later than six months prior to the period of extended operation (i.e., by April 17, 2026).
The amendment request is subdivided as follows:
- provides an evaluation of the proposed change.
- provides a markup of the affected Braidwood Unit 1 RFOL page.
The proposed change has been reviewed by Braidwood Plant Operations Review Committee in accordance with the requirements of the CEG Quality Assurance Program.
October 3, 2025 U.S. Nuclear Regulatory Commission Page 2 CEG requests approval of the proposed change by March 17, 2026. Once approved the amendment shall be implemented within 30 days.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),
CEG is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its attachment to the designated State Official.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this submittal, please contact Ms. Erin Whitsell at (779) 231-8262.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 3rd day of October 2025.
Respectfully, Rebecca L. Steinman Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments:
1.
Evaluation of the Proposed Change 2.
Markup of Renewed Facility Operating License Page cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector - Braidwood Station NRC Project Manager, NRR - Braidwood Station Illinois Emergency Management Agency - Division of Nuclear Safety Steinman, Rebecca Lee Digitally signed by Steinman, Rebecca Lee Date: 2025.10.03 10:58:57 -05'00'
ATTACHMENT 1 Evaluation of the Proposed Changes Page 1 of 6
Subject:
Application for Amendment to Renewed Facility License to Revise License Conditions 2.C(13)(b)(1) and 2.C(13)(b)(2) 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Proposed Change 2.2 Need for Change
3.0 TECHNICAL EVALUATION
3.1 Background
3.2 Aging Management
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusion
5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
Page 2 of 6 ATTACHMENT 1 Evaluation of the Proposed Changes 1.0
SUMMARY
DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Renewed Facility Operating License (RFOL) No. NPF-72 for Braidwood Station, Unit 1 (Braidwood). The proposed change revises license conditions 2.C(13)(b)(1) and 2.C(13)(b)(2) to extend the completion date of License Renewal Commitment 30 Enhancements 2 and 3 to October 16, 2026. These commitments, which are listed in Appendix A of Reference 1, are related to ASME Section XI, Subsection IWL program enhancements and inspections of containment tendons that are currently required to be completed no later than six months prior to the period of extended operation (i.e., by April 17, 2026).
The proposed extension is needed to accommodate unavailability of qualified individuals to perform the inspections to which Braidwood has committed under License Renewal Commitment 30 Enhancements 2 and 3.
2.0 DETAILED DESCRIPTION 2.1 Proposed Change The proposed change to Braidwood Unit 1 RFOL is being requested as described below.
License Conditions 2.C(13)(b)(1) and 2.C(13)(b)(2) currently state:
1.
The licensee shall implement those new programs and enhancements to existing programs no later than April 17, 2026.
2.
The Licensee shall complete those activities as noted in the Commitments applicable to Braidwood Unit 1 in this Supplement no later than April 17, 2026 or the end of the last refueling outage prior to the period of extended operation, whichever occurs later.
The revised License Conditions 2.C(13)(b)(1) and 2.C(13)(b)(2) will state:
1.
The Licensee shall implement those new programs and enhancements to existing programs no later than April 17, 2026, as modified by the following exception:
a.
The existing ASME Section XI, Subsection IWL, program shall be enhanced to address the items documented in License Renewal Commitment 30, Items 2 and 3, no later than October 16, 2026.
ATTACHMENT 1 Evaluation of the Proposed Changes Page 3 of 6 2.
The Licensee shall complete those activities as noted in the Commitments applicable to Braidwood Unit 1 in this Supplement no later than April 17, 2026 or the end of the last refueling outage prior to the period of extended operation, whichever occurs later, and as modified by the following exception:
a.
The pre-period of extended operation inspections specified in License Renewal Commitment 30 Enhancements 2 and 3 shall be completed no later than October 16, 2026. provides the existing RFOL page for Braidwood Unit 1, marked up to show the proposed change.
2.2 Need for Change Braidwood is unable to complete the inspections in License Renewal Commitment 30 Enhancements 2 and 3 by the date to which they were committed for Unit 1. The proposed change extends the date of these inspections to support availability of a qualified vendor, as Braidwood does not have the equipment nor technical expertise to perform these inspections in-house.
3.0 TECHNICAL EVALUATION
3.1 Background
Under License Renewal Commitment 30 Enhancements 2 and 3, Braidwood has committed to performing Unit 1 inspections by April 17, 2026 (i.e., six months prior to entry into the PEO for Unit 1). These inspections require equipment and technical expertise that Braidwood personnel do not have and therefore must be performed by an external vendor. Precision Surveillance Corporation (PSC) has been the sole vendor available for ASME Section XI IWL inspections for Braidwood. PSC provides these services for most commercial nuclear power plants in the United States. Because of this, there is limited qualified inspector availability for performance of the extensive inspections (months to complete) to which Braidwood has committed. As a result, scheduling for this work has been delayed to the summer of 2026, after the April 17, 2026 commitment date.
Upon commitment to the License Renewal inspections, scheduling of these inspections was planned to coincide with the 35th year ASME Section XI IWL inspections, which were planned for execution in 2021. Initial actions and planning were completed and closed with this schedule in mind. However, CEG was granted a relief request in 2021 to extend the interval between post-tensioning system examinations and testing and detailed visual examination of concrete adjacent to tendon bearing plates from 5 years to 10 years, which resulted in the license renewal inspections not being performed in 2021 and being rescheduled to coincide with the 40th year ASME Section XI IWL inspections (Reference 2).
The 40th year IWL examination window, bounded by overlap between both Unit 1 and Unit 2 per IWL-2420, does not begin until September 2026 and this was not accounted for when the License Renewal inspections were rescheduled.
ATTACHMENT 1 Evaluation of the Proposed Changes Page 4 of 6 3.2 Aging Management Inspections to which Braidwood has committed will be performed as described in the License Renewal commitments without alteration, except for the date by which they will be performed. This will result in the same output data. Due to the frequency of the inspections in Enhancement 3, the proposed delay of six months, solely for Unit 1, is not expected to impact the Aging Management Program. In addition, the inspections will still be completed prior to entering the PEO for Unit 1.
4.0 REGULATORY ANALYSIS
4.1 Applicable Regulatory Requirements/Criteria The proposed change only affects the schedule for performing the inspections listed in License Renewal Commitment 30 Enhancements 2 and 3. There is no impact to ASME Code requirements.
4.2 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Renewed Facility Operating License (RFOL) No. NPF-72 for Braidwood Station, Unit 1 (Braidwood). The proposed change revises license conditions 2.C(13)(b)(1) and 2.C(13)(b)(2) to extend the completion date of License Renewal Commitment 30 Enhancements 2 and 3 to October 16, 2026. These commitments, which are listed in Appendix A of the Reference, are related to ASME Section XI, Subsection IWL program enhancements and inspections of containment tendons that are currently required to be completed no later than six months prior to the period of extended operation (i.e., by April 17, 2026).
CEG has evaluated the proposed change against the criteria of 10 CFR 50.92(c) criteria to determine if the proposed change results in any significant hazards. The following is the evaluation of each of the 10 CFR 50.92(c) criteria:
1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change is an administrative 6-month extension of the inspection performance due date for Braidwood, Unit 1. The proposed change does not involve a change to any plant equipment that initiates or mitigates an accident.
Therefore, the proposed change does not affect the functionality of the associated structures, systems, and components (SSC) in the aging management programs (AMP).
Therefore, the proposed change does not involve a significant increase in the
ATTACHMENT 1 Evaluation of the Proposed Changes Page 5 of 6 probability or consequences of an accident previously evaluated.
2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change is an administrative 6-month extension of the inspection performance due date for Braidwood, Unit 1. The proposed change does not modify or add any equipment or involve controlling or operating equipment.
There are no postulated hazards, new or different, associated with the proposed change because there is no impact to the design or operational requirements of any SSC. The proposed change does not create the possibility of a new or different kind of accident because there are no credible new failure mechanisms, malfunctions, or accident initiators.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change is an administrative 6-month extension of the inspection performance due date for Braidwood, Unit 1. The proposed change does not change any of the controlling values of parameters used to avoid exceeding regulatory or licensing limits. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, CEG concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
ATTACHMENT 1 Evaluation of the Proposed Changes Page 6 of 6
5.0 ENVIRONMENTAL CONSIDERATION
CEG has determined that the proposed amendments would change requirements with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.
However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.
6.0 REFERENCES
1.
NUREG-2190, "Safety Evaluation Report Related to the License Renewal of Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, Volume 2," dated December 2015 (ADAMS Accession No. ML15350A041) 2.
Letter from U.S. Nuclear Regulatory Commission to David P. Rhoades (Constellation Energy Generation, LLC), "Braidwood Station, Units 1 and 2 and Byron Station, Unit Nos. 1 and 2 - Proposed Alternative to the Requirements of The American Society of Mechanical Engineers Boiler &
Pressure Vessel Code (EPIDS L-2020-LLR-0099 and L-2020-LLR-0100),"
dated August 13, 2021 (ADAMS Accession No. ML21134A006)
ATTACHMENT 2 Braidwood Station, Unit 1 Renewed Facility Operating License No. NPF-72 NRC Docket No. STN 50-457 Markup of Renewed Facility Operating License Page
5HQHZHG/LFHQVH1R13)
$PHQGPHQW1R
E
2SHUDWLRQVWRPLWLJDWHIXHOGDPDJHFRQVLGHULQJWKHIROORZLQJ
3URWHFWLRQDQGXVHRISHUVRQQHODVVHWV
&RPPXQLFDWLRQV
0LQLPL]LQJILUHVSUHDG
3URFHGXUHVIRULPSOHPHQWLQJLQWHJUDWHGILUHUHVSRQVH
VWUDWHJ\\
,GHQWLILFDWLRQRIUHDGLO\\DYDLODEOHSUHVWDJHGHTXLSPHQW
7UDLQLQJRQLQWHJUDWHGILUHUHVSRQVHVWUDWHJ\\
6SHQWIXHOSRROPLWLJDWLRQPHDVXUHV
F
$FWLRQVWRPLQLPL]HUHOHDVHWRLQFOXGHFRQVLGHUDWLRQRI
- DWHUVSUD\\VFUXEELQJ
'RVHWRRQVLWHUHVSRQGHUV
/LFHQVH5HQHZDO/LFHQVH&RQGLWLRQV
D
7KHLQIRUPDWLRQLQWKH8)6$5VXSSOHPHQWVXEPLWWHGSXUVXDQWWR
&)5 G DVUHYLVHGGXULQJWKHOLFHQVHUHQHZDO
DSSOLFDWLRQUHYLHZSURFHVVDQGDVVXSSOHPHQWHGE\\WKH
&RPPLWPHQWVDSSOLFDEOHWR%UDLGZRRG8QLWLQ$SSHQGL[$RIWKH
³6DIHW\\(YDOXDWLRQ5HSRUW5HODWHGWRWKH/LFHQVH5HQHZDORI
%\\URQ6WDWLRQ8QLWVDQGDQG%UDLGZRRG6WDWLRQ8QLWV
DQG' 6(5 GDWHG-XO\\LVFROOHFWLYHO\\WKH³/LFHQVH
5HQHZDO8)6$56XSSOHPHQW'7KLV6XSSOHPHQWLVKHQFHIRUWK
SDUWRIWKH8)6$5ZKLFKZLOOEHXSGDWHGLQDFFRUGDQFHZLWK
&)5 H $VVXFKWKHOLFHQVHHPD\\PDNHFKDQJHVWR
WKHSURJUDPVDQGDFWLYLWLHVDSSOLFDEOHWR%UDLGZRRG8QLW
GHVFULEHGLQWKLV6XSSOHPHQWSURYLGHGWKHOLFHQVHHHYDOXDWHV
VXFKFKDQJHVSXUVXDQWWRWKHFULWHULDVHWIRUWKLQ&)5
DQGRWKHUZLVHFRPSOLHVZLWKWKHUHTXLUHPHQWVLQWKDWVHFWLRQ
E
7KLV/LFHQVH5HQHZDO8)6$56XSSOHPHQWDVUHYLVHGSHU
/LFHQVH&RQGLWLRQ D DERYHGHVFULEHVFHUWDLQSURJUDPVWREH
LPSOHPHQWHGDQGDFWLYLWLHVWREHFRPSOHWHGSULRUWRWKHSHULRGRI
H[WHQGHGRSHUDWLRQ
7KHOLFHQVHHVKDOOLPSOHPHQWWKRVHQHZSURJUDPVDQG
HQKDQFHPHQWVWRH[LVWLQJSURJUDPVQRODWHUWKDQ
$SULO
7KHOLFHQVHHVKDOOFRPSOHWHWKRVHDFWLYLWLHVDVQRWHGLQWKH
&RPPLWPHQWVDSSOLFDEOHWR%UDLGZRRG8QLWLQWKLV
6XSSOHPHQWQRODWHUWKDQ$SULORUWKHHQGRIWKH
ODVWUHIXHOLQJRXWDJHSULRUWRWKHSHULRGRIH[WHQGHG
RSHUDWLRQZKLFKHYHURFFXUVODWHU
7KHOLFHQVHHVKDOOQRWLI\\WKH15&LQZULWLQJZLWKLQGD\\V
DIWHUKDYLQJDFFRPSOLVKHGLWHP E DERYHDQGLQFOXGHWKH
VWDWXVRIWKRVHDFWLYLWLHVWKDWKDYHEHHQRUUHPDLQWREH
FRPSOHWHGLQLWHP E DERYH
- a. The existing ASME Section XI, Subsection IWL, program shall be enhanced to address the items documented in License Renewal Commitment 30, Items 2 and 3, no later than October 16, 2026.
- a. The pre-period of extended operation inspections specified in License Renewal Commitment 30 Enhancements 2 and 3 shall be completed no later than October 16, 2026.
, and as modified by the following exception:
, as modified by the following exception: