Text

Application to Adopt Changes to the Quadrant Power Tilt Ratio Technical Specification
	ML25346A095
Person / Time
Site:	Braidwood, Byron
Issue date:	12/12/2025
From:	Steinman R; Constellation Energy Generation
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML25346A094	List: RS-25-153, Application to Adopt Changes to the Quadrant Power Tilt Ratio Technical Specification;
References
	RS-25-153
	Download: ML25346A095 (0)
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4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 contains Proprietary Information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachment 1, this document is decontrolled.

10 CFR 50.90 RS-25-153 December 12, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 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

Subject:

Application to Adopt Changes to the Quadrant Power Tilt Ratio Technical Specification 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 the Technical Specifications (TS) for Braidwood, Units 1 and 2, and Byron, Units 1 and 2.

CEG requests changes to the Braidwood Unit 1 and Unit 2 TS and Byron Unit 1 and Unit 2 TS. This license amendment revises the TS requirements associated with TS 3.2.4, "Quadrant Power Tilt Ratio (QPTR)." provides a description and evaluation of the proposed changes. Attachments 4 and 5 provide the existing TS pages marked up to show the proposed TS changes.

Attached 1 contains information proprietary to Framatome. The affidavit, provided in Attachment 3, sets forth the basis on which Framatomes information may be withheld from public disclosure by the U.S. Nuclear Regulatory Commission (NRC) and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Accordingly, it is respectfully requested that the information that is proprietary to Framatome be withheld from public disclosure in accordance with 10 CFR 2.390.

Proprietary information is indicated by text included within (( bold double brackets )). provides the non-proprietary version of the description and evaluation of the proposed changes.

The proposed changes have been reviewed by the Braidwood and Byron Plant Operations Review Committees, in accordance with the requirements of the CEG Quality Assurance Program.

December 12, 2025 U.S. Nuclear Regulatory Commission Page 2 CEG requests approval of the proposed amendment by June 1, 2026. Once approved, the amendment shall be implemented within 90 days for Braidwood Units 1 and 2 and Byron Unit 1.

The amendment shall be implemented at Byron Unit 2 within 30 days of the implementation of Byron Amendment 238, which removes the use of the Power Distribution Monitoring System from the TS (ADAMS Accession No. ML24352A075).

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 attachments to the designated State Official.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 12th day of December 2025.

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mrs. Kathrine Laureto, 779-231-7394.

Respectfully, Rebecca L. Steinman Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:

1.

Evaluation of Proposed Changes (Proprietary) 2.

Evaluation of Proposed Changes (Non-Proprietary) 3.

Framatome Affidavit 4.

Proposed Technical Specifications Changes (Mark-up), Braidwood, Units 1 and 2 5.

Proposed Technical Specifications Changes (Mark-up), Byron, Units 1 and 2 cc:

NRC NRR Project Manager - Braidwood / Byron NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood NRC Senior Resident Inspector - Byron Illinois Emergency Management Agency - Division of Nuclear Safety

Steinman, Rebecca Lee Digitally signed by Steinman, Rebecca Lee Date: 2025.12.10 16:06:46

-06'00'

ATTACHMENT 2 Evaluation of Proposed Changes (Non-Proprietary)

ATTACHMENT 2 Page 1 of 10

Subject:

Application to Adopt Changes to the Quadrant Power Tilt Ratio Technical Specification 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specifications Requirements 2.3 Reason for Proposed Change 2.4 Description of Proposed Change 2.5 Limitations and Conditions 2.6 Variations

3.0 TECHNICAL EVALUATION

3.1 Add Note to LCO 3.2.4 3.2 Revise QPTR Value in Required Action A.1 3.3 Revise 12 Hour Frequency for SR 3.2.4.2

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

ATTACHMENT 2 Page 2 of 10

1.

SUMMARY

DESCRIPTION Constellation Energy Generation, LLC (CEG) requests changes to the Braidwood Unit 1 and Unit 2 TS and Byron Unit 1 and Unit 2 TS. This license amendment revises the TS requirements associated with TS 3.2.4, "Quadrant Power Tilt Ratio (QPTR)." The proposed change to Braidwood and Byron TS is similar to changes described in PWROG-22021-P-A/NP-A, Revision 0, (Reference 1) which was approved by the U.S.

Nuclear Regulatory Commission (NRC) on May 29, 2025 (Reference 2).

2. DETAILED DESCRIPTION 2.1 System Design and Operation The core power distribution during operation is an assumption in the safety analyses. The core power distribution is predicted based on the fuel loading and verified by measurement during the fuel cycle. The core power distribution changes slowly during the cycle as fuel burnup is accumulated. The Heat Flux Hot Channel Factor, FQ(Z), and the Nuclear Enthalpy Rise Hot Channel Factor, F

, are the core peaking factors that are measured periodically during operation to ensure the safety analysis core power distribution assumptions are met.

The primary purpose of QPTR is to detect changes in the radial power distribution between calibrated states. It ensures that the previously measured core peaking factors are within their Limiting Condition for Operation (LCO) limits. The Nuclear Instrumentation System (NIS) Power Range (PR) Neutron Flux detectors (the excore detectors designated as N-41, N-42, N-43, and N-44) are used to measure the QPTR. Each NIS PR Neutron Flux detector channel has an upper and lower chamber. The QPTR is the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater. The "calibrated output" of each PR channel is adjusted when the incore power distribution is measured to indicate a QPTR near one. A QPTR value of 1.0 does not represent a zero incore power tilt, but rather indicates that the radial power distribution, as measured by the excore detectors, is consistent with the incore power distribution (including any existing incore power tilt) that was measured during the calibration. A QPTR value greater than 1.02 may indicate that a change has occurred in the gross radial power distribution but does not necessarily mean that the core peaking factors have exceeded their LCO limits. The startup full power currents for a new fuel cycle are determined by procedure based on predicted power distributions until the initial operating measurement can be performed. A QPTR value other than 1.0 at the beginning of a new cycle does not necessarily indicate an abnormal condition.

The NIS excore channels continuously monitor QPTR, and an alarm is generated if it exceeds 1.02. A QPTR not within the TS limit of 1.02 indicates the core power distribution may have changed more significantly than anticipated since the last incore power distribution measurement and actions are required to ensure the safety analysis assumptions are still met.

ATTACHMENT 2 Page 3 of 10 2.2 Current Technical Specifications Requirements TS 3.2.4, "QPTR," requires the QPTR to be 1.02 when the reactor is in MODE 1 with thermal power > 50% of Rated Thermal Power (RTP).

Surveillance Requirement (SR) 3.2.4.1 requires verification that QPTR is within its limit in accordance with the Surveillance Frequency Control Program (SFCP). SR 3.2.4.2, which may be performed in lieu of SR 3.2.4.1, requires verification that the QPTR is within limit using the movable incore detector system. SR 3.2.4.2 is used when one or more PR Neutron Flux channels are inoperable and thermal power is > 75% RTP.

If the measured QPTR is not within its limit, several actions are required:

x Thermal power must be reduced by 3% for each 1% that QPTR is greater than 1.0 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ; x

The updated QPTR must be determined within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; x

The core peaking factors, FQ(Z) and F

, must be measured within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving an equilibrium condition after the power reduction, and once per 7 days thereafter; x

Prior to increasing thermal power, the safety analyses must be reevaluated to confirm the results remain valid for the duration of operation under the condition; x

Prior to increasing thermal power, the excore detectors are normalized to restore QPTR to within limit; and x

The core peaking factors, FQ(Z) and F

, must be measured within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving an equilibrium condition, and within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after increasing thermal power.

2.3 Reason For Proposed Change The proposed change addresses several issues related to QPTR:

x The QPTR limit currently applies before the excore detectors have been calibrated at the beginning of a fuel cycle, and, as a result, the measured QPTR may not be indicative of the incore power distribution. This proposed change aligns the applicability of LCO 3.2.4 to after the incore-excore calibration for a new cycle is performed by SR 3.3.1.6. This eliminates the need to use predicted values that are not representative of the new core.

x The proposed change to modify the limit from 1.00 to 1.02 minimizes the power reduction if QPTR exceeds its limit. Safety analysis assumptions are adequately protected between QPTR values of 1.00 to 1.02, therefore thermal power reduction required should only be based on the amount the QPTR limit is exceeded.

x Required measurement of the QPTR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months using the movable incore detector system when an excore channel is inoperable results in significant wear on the system and is unnecessary if any control rod movement is monitored. The proposed change eliminates the recurring need to operate the movable incore detector system every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and reduces the wear on the system.

ATTACHMENT 2 Page 4 of 10 2.4 Description of Proposed Change The following changes are made to TS 3.2.4, "QPTR:

x The LCO is revised by the addition of a Note which states that the QPTR limit is not required to be met following refueling until after the initial performance of SR 3.3.1.6, which performs an incore/excore detector calibration.

x Required Action A.1, which requires a reduction in thermal power by at least 3% from RTP for each 1% that QPTR exceeds 1.0, is revised to state that the reduction is 3% in thermal power for each 1% that QPTR exceeds the limit of 1.02.

x Editorial improvements are made to Note 1 of SR 3.2.4.1.

x SR 3.2.4.1, Note 2, is revised from stating that SR 3.2.4.2 may be performed in lieu of SR 3.4.2.1 to stating that the movable incore detector system can be used to determine QPTR.

x SR 3.4.2.1 is revised to remove a requirement that the QPTR be verified to be within its limit "by calculation."

x SR 3.2.4.2, which requires verifying QPTR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months using the movable incore detector system when one or more Power Range Neutron Flux channels are inoperable and thermal power if greater than 75% RTP, is eliminated.

x SR 3.4.2.1 is revised by the addition of a new Frequency which replaces SR 3.2.4.2. The new Frequency requires verification of QPTR once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months following any rod motion of at least 12 steps if the associated rod position indicator is inoperable. The new Frequency is modified by a Note that states it is only required to be performed if the calibrated output of one excore detector is unavailable and thermal power is greater than 75% RTP.

The Braidwood and Byron TS Bases will be revised in accordance with the TS 5.5.14, "Technical Specification (TS) Bases Control Program," to reflect the proposed corresponding changes to the TS as part of the implementation of the approved Amendment.

2.5 Limitations and Conditions The proposed change to Braidwood and Byron TS is similar to changes described in PWROG-22021-P-A/NP-A, Revision 0, "Justifications for the Proposed Changes to the Quadrant Power Tilt Ratio Technical Specification." CEG has reviewed PWROG-22021-P-A.

In accordance with PWROG-22021 Section 4.0, "Limitation and Conditions," of the NRC safety evaluation, CEG provides the following verifications:

The reload methodology for Braidwood and Byron Vantage+ fuel is based on WCAP-9272-P-A (Reference 3). Starting from Braidwood 1 Cycle 26, GAIA fuel will be introduced in both Byron and Braidwood units. The reload methods referenced in TS 5.6.5.b, "Core Operating Limits Report," References 14-27, have been approved as licensing methods for GAIA fuel (Reference 4).

ATTACHMENT 2 Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390(a)(4)

Page 5 of 10 The peaking factor uncertainties documented in the Braidwood and Byron TS 5.6.5.b, "Core Operating Limits Report," remain unchanged for the GAIA fuel transition. Both Westinghouse and Framatome reload methods are in compliance. Within Framatomes methods, the predicted radial and axial peaking factors are benchmarked against the measured peaking factors, ((

)) Consequently, ((

)) (Reference 5, Section 2.2.1). This ensures that the safety analysis remains valid for up to 2% excore tilt.

CEG confirms that the Reactor Protection System (RPS) and Nuclear Instrumentation (NI) circuitry for Braidwood and Byron align with the information provided in PWROG-22021-P-A.

The transition to GAIA fuel does not impact the RPS and NI circuitry. All GAIA transients have been performed to demonstrate compliance with the existing RPS setpoints.

The timeline of Braidwood and Byron transitions from Westinghouse to GAIA fuel is listed below. Both Framatome and Westinghouse methods will continue to be used until the reactor core is fully transitioned to GAIA fuel.

x Fall Outage 2025: Braidwood Unit 1 Cycle 26 x

Spring Outage 2026: Braidwood Unit 2 Cycle 26 x

Spring Outage 2026: Byron Unit 1 Cycle 28 x

Fall Outage 2026: Byron Unit 2 Cycle 27 2.6 Variations CEG is proposing the following variation from the TS changes described in topical report PWROG-22021-P-A/NP-A.

PWROG-22021 includes a proposed change to remove Required Actions D.1.2, D.2.1, and D.2.2 from TS 3.3.1, "Reactor Trip System (RTS) Instrumentation" (Reference 1, Section 8). The changes to TS 3.3.1 are not applicable to the Braidwood and Byron TS because the suggested changes already exist in the TS. In the current Braidwood and Byron TS 3.3.1, there is one Required Action which is D.1, "place channel in trip."

PWROG-22021 also includes a proposed change to Required Action A.1 from TS 3.2.4, "QPTR."

In the topical report, Required Action A.1 is relabeled Required Action A.1.1 and is joined by a logical OR to a new Required Action A.1.2. Required Action A.1.2 requires reducing the peaking factor limits. This alternative allows continuous operation at full power instead of requiring a power reduction any time the QPTR exceeds the LCO limit. CEG is choosing not to adopt the addition of alternative Required Action A.1.2. The exclusion of Required Action A.1.2 in this amendment request does not affect the other changes being implemented.

In PWROG-22021, SR 3.2.4.2 is removed and incorporated into SR 3.2.4.1. The Frequency of the updated SR 3.2.4.1 is modified as a result. CEG is adding a statement to the SR 3.2.4.1 Frequency to clarify that the incore movable detector system should be used if an associated digital rod position indicator is inoperable. While this statement is implied and added as SR 3.2.4.1 Note 2 in PWROG-22021, CEG is choosing to explicitly state this in the Surveillance Requirement Frequency.

ATTACHMENT 2 Page 6 of 10 CEG is removing the word the from the Completion Times of Required Actions A.4 and A.6. This is done to match the TS Completion Time verbiage from the Westinghouse Standard Technical Specifications in NUREG-1431, Revision 5.0.

3. TECHNICAL EVALUATION The technical justification for the proposed changes is provided in PWROG-22021-P-A/NP-A.

Therefore, this LAR only discusses how the approved justification applies to Braidwood and Byron.

3.1 Add Note to LCO 3.2.4 One proposed change to TS 3.2.4 is to add a Note stating that LCO 3.2.4 is not applicable until the initial calibration of the excore channels is performed per SR 3.3.1.6 following refueling (Reference 1, Section 4).

In the NRC safety evaluation for PWROG-22021-P-A/NP-A, Section 3.1, the NRC found that the addition of the proposed Note to LCO 3.2.4 is justified because the full power currents for the new cycle are not determined until the first incore-excore calibration is performed per SR 3.3.1.6. This LCO would similarly not apply for a new fuel cycle following a refueling outage at Braidwood and Byron until SR 3.3.1.6 is performed. Performance of this SR ensures that the full power currents used by the PR NIS to calculate the QPTR are representative of the new core. This change is also justified by Section 2.5 of this amendment request, "PWROG-22021 Limitations and Conditions."

3.2 Revise QPTR Value in Required Action A.1 One proposed change to TS 3.2.4 is to revise the QPTR value of 1.00 to 1.02 in Required Action A.1 (Reference 1, Section 5).

In the NRC safety evaluation for PWROG-22021-P-A/NP-A, Section 3.2, the NRC found that the reload safety analysis methodologies conservatively bound a QPTR value up to 1.02. The QPTR limit of 1.02 provides a margin of protection for both the departure from nucleate boiling (DNB) ratio and the linear heat generation rate. The peaking factor uncertainties documented in the Braidwood and Byron TS 5.6.5.b, "Core Operating Limits Report," remain unchanged for the GAIA fuel transition. Both Westinghouse and Framatome reload methods are in compliance.

The NRC agreed that there is no need to reduce power for a QPTR value between 1.00 and 1.02 because the 1.02 value does not result in challenging the core peaking factor limits. This conclusion is applicable to the core peaking factor limits at Braidwood and Byron.

3.3 Revise the 12 Hour Frequency for SR 3.2.4.2 One aspect of the proposed change to TS 3.2.4 is to delete SR 3.2.4.2 and incorporate it into SR 3.2.4.1 as an additional Frequency (Reference 1, Section 7). Under the proposed change, the monitoring required by SR 3.2.4.1 and SR 3.2.4.2 is combined since both require a periodic verification that the QPTR is within its limit. In lieu of the SR 3.2.4.2 requirement to determine

ATTACHMENT 2 Page 7 of 10 QPTR using the movable incore detector system every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a new Frequency is added to SR 3.2.4.1.

In the NRC safety evaluation for PWROG-22021-P-A/NP-A, Section 3.5, the NRC found that the consolidated SR is acceptable. At Braidwood and Byron, the consolidated SR will continue to provide assurance that the necessary quality of systems and components is maintained, such that facility operation will be within safety limits, and that the LCOs will be met.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Regulation 10 CFR 50.36(c), Paragraph (2), states that when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. The proposed change provides a remedial action to be taken when the limiting condition for operation is not met and is in compliance with 10 CFR 50.36(c)(2).

Regulation 10 CFR 50.36(c), Paragraph (3), states that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed change revises the surveillance requirements while ensuring the limiting conditions for operation will be met, and is in compliance with 10 CFR 50.36(c)(3).

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

The regulation at 10 CFR 50.36(a)(1) requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." This license amendment request will revise the Bases to be consistent with the changes to the TS and therefore complies with 10 CFR 50.36(a)(1).

ATTACHMENT 2 Page 8 of 10 4.2 No Significant Hazards Consideration CEG has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the TS requirements associated with the QPTR.

A QPTR value outside the TS LCO limit or an unavailable Power Range Neutron Flux -

High channel are not initiators of any accident previously evaluated. The actions taken when the QPTR is not within limit or a Power Range Neutron Flux - High channel is unavailable are not initiators to any accident previously evaluated. As a result, the proposed change does not significantly increase the probability of an accident previously evaluated.

The actions taken when the QPTR is not within limit or a Power Range Neutron Flux -

High channel is unavailable are not mitigating actions assumed in any previously analyzed accident. As a result, the consequences of any previously analyzed accident are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the 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 revises the TS requirements associated with the QPTR.

The proposed change only applies when the QPTR LCO limit is not met or a Power Range Neutron Flux - High channel is unavailable. The QPTR LCO limit continues to be required to be met and the Power Range Neutron Flux - High channels that provide a reactor trip continue to be required to be operable. Actions taken when a TS limit is not met or equipment is inoperable is not credited in the safety analysis and, as a result, the change to the actions are not a precursor to a new or different kind of accident, and does not initiate any new or different kinds of accidents not considered in the design and licensing bases.

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

ATTACHMENT 2 Page 9 of 10 The proposed change revises the TS requirements associated with the QPTR.

The proposed change does not change the safety function of any plant equipment and does not impact any design basis accident inputs or assumptions. The proposed change does not affect any specific values that define margin as established in each plants licensing basis.

The proposed change does not alter a design basis or safety limit (i.e., the controlling numerical value for a parameter established in the UFSAR or the license), and as a result, does not significantly reduce the margin of safety.

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 presents no 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 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION A CEG review has determined that the proposed change would alter a requirement 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 change does 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 amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). In accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6. REFERENCES

1. PWROG Topical Report PWROG-22021-P-A/NP-A, Revision 0, "Justifications for the Proposed Changes to the Quadrant Power Tilt Ratio Technical Specification," August 2025, (ADAMS Accession No. ML25231A218).

ATTACHMENT 2 Page 10 of 10

2. Email from Leslie Fields (NRC) to Dewey Olinski (Westinghouse), "NRC Transmittal of the Final Safety Evaluation for Pressurized Water Reactor Owners Group Topical Report (TR) PWROG-22021-P, Revision 0, 'Justifications for the Proposed Changes to the Quadrant Power Tilt Ratio Technical Specification'," dated May 29, 2025, (ADAMS Accession No. ML25148A288).

3. Westinghouse Electric Corporation, Topical Report WCAP-9272-P-A, Revision 0, "Westinghouse Reload Safety Evaluation Methodology," March 1978 (ADAMS Accession No. ML051390150).

4. NRC Safety Evaluation Report, Braidwood Station, Units 1 and 2; and Byron Station, Units 1, and 2 - Issuance of Amendments to Revise Technical Specifications to use Framatome GAIA Fuel (EPID L-2024-LLA-0072), August 21, 2025 (ADAMS Accession No. ML25148A202).

5. Framatome, Topical Report ANP-4087P, Revision 1, "Byron and Braidwood Non-LOCA Summary Report with ARITA Methodology," August 2025 (Attachment 17 to RS-24-044 in ADAMS Accession No. ML24149A125).

ATTACHMENT 3 Framatome Affidavit

A F F I D A V I T

1.

My name is Morris Byram. I am Manager, Licensing & Regulatory Affairs for Framatome Inc. (Framatome) and as such I am authorized to execute this Affidavit.

2.

I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.

3.

I am familiar with the Framatome information contained in Attachment 1 to CEG letter RS-25-153, with subject Application to Adopt Changes to the Quadrant Power Tilt Ratio Technical Specification, and referred to herein as Document. Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.

4.

This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5.

This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.

ATTACHMENT 3

6.

The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:

(a)

The information reveals details of Framatomes research and development plans and programs or their results.

(b)

Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c)

The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.

(d)

The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.

(e)

The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.

The information in this Document is considered proprietary for the reasons set forth in paragraph 6(d) and 6(e) above.

7.

In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8.

Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9.

The foregoing statements are true and correct to the best of my knowledge, information, and belief.

ATTACHMENT 3

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: (12/9/2025)

(NAME) morris.byram@framatome.com 2101 Horn Rapids Road Richland, WA 99354 BYRAM Morris Digitally signed by BYRAM Morris Date: 2025.12.09 08:49:26 -08'00' ATTACHMENT 3

ATTACHMENT 4 Proposed Technical Specifications Changes (Mark-up)

Braidwood, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 3.2.4-1 3.2.4-2 3.2.4-3 3.2.4-4

QPTR 3.2.4 BRAIDWOOD UNITS 1 & 2 3.2.4 1 Amendment 239 3.2 POWER DISTRIBUTION LIMITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

LCO 3.2.4 The QPTR shall be 1.02.

APPLICABILITY:

MODE 1 with THERMAL POWER > 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

QPTR not within limit.

A.1 Reduce THERMAL POWER 3% from RTP for each 1% of QPTR

> 1.020.

AND A.2 Determine QPTR.

AND A.3 Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each QPTR determination Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 24 hours after achieving equilibrium conditions from a THERMAL POWER reduction per Required Action A.1 AND Once per 7 days thereafter (continued)

NOTE---------------------------

The QPTR limit is not required to be met following refueling until after initial performance of SR 3.3.1.6.

QPTR 3.2.4 BRAIDWOOD UNITS 1 & 2 3.2.4 2 Amendment 239 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.4 Re-evaluate safety analyses and confirm results remain valid for duration of operation under this condition.

AND A.5

NOTES--------

1.

Perform Required Action A.5 only after Required Action A.4 is completed.

2.

Required Action A.6 shall be completed whenever Required Action A.5 is performed.

Normalize excore detectors to restore QPTR to within limits.

AND Prior to increasing the THERMAL POWER above the limit of Required Action A.1 Prior to increasing the THERMAL POWER above the limit of Required Action A.1 (continued)

QPTR 3.2.4 BRAIDWOOD UNITS 1 & 2 3.2.4 3 Amendment 239 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.6

NOTE---------

Perform Required Action A.6 only after Required Action A.5 is completed.

Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after exceeding the THERMAL POWER limit of Required Action A.1 B.

Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to 50% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

QPTR 3.2.4 BRAIDWOOD UNITS 1 & 2 3.2.4 4 Amendment 239 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1

NOTES--------------------

1.

With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER 75% RTP, the remaining three power range channel inputs can be used for calculating QPTR.

2.

SR 3.2.4.2 may be performed in lieu of this Surveillance.

Verify QPTR is within limit by calculation. In accordance with the Surveillance Frequency Control Program SR 3.2.4.2

NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after input from one Power Range Neutron Flux channel is inoperable with THERMAL POWER > 75% RTP.

Verify QPTR is within limit using the movable incore detectors.

In accordance with the Surveillance Frequency Control Program AND

NOTE----------------------------------

Only required to be performed if calibrated output of one Power Range Neutron Flux channel is unavailable, and THERMAL POWER > 75% RTP.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months following any rod motion 12 steps if an associated digital rod position indicator is inoperable using the movable incore detector system.

The movable incore detector system can be used to determine QPTR.

With the calibrated output of one Power Range Neutron Flux channel unavailable and THERMAL POWER 75% RTP, the remaining three Power Range Neutron Flux channels can be used to determine QPTR.

ATTACHMENT 5 Proposed Technical Specifications Changes (Mark-up)

Byron, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 3.2.4-1 3.2.4-2 3.2.4-3 3.2.4-4

QPTR 3.2.4 BYRON UNITS 1 & 2 3.2.4 1 Amendment 238 3.2 POWER DISTRIBUTION LIMITS 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

LCO 3.2.4 The QPTR shall be 1.02.

APPLICABILITY:

MODE 1 with THERMAL POWER > 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

QPTR not within limit.

A.1 Reduce THERMAL POWER 3% from RTP for each 1% of QPTR

> 1.020.

AND A.2 Determine QPTR.

AND A.3 Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each QPTR determination Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 24 hours after achieving equilibrium conditions from a THERMAL POWER reduction per Required Action A.1 AND Once per 7 days thereafter (continued)

NOTE---------------------------

The QPTR limit is not required to be met following refueling until after initial performance of SR 3.3.1.6.

QPTR 3.2.4 BYRON UNITS 1 & 2 3.2.4 2 Amendment 238 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.4 Re-evaluate safety analyses and confirm results remain valid for duration of operation under this condition.

AND A.5

NOTES--------

1.

Perform Required Action A.5 only after Required Action A.4 is completed.

2.

Required Action A.6 shall be completed whenever Required Action A.5 is performed.

Normalize excore detectors to restore QPTR to within limits.

AND Prior to increasing the THERMAL POWER above the limit of Required Action A.1 Prior to increasing the THERMAL POWER above the limit of Required Action A.1 (continued)

QPTR 3.2.4 BYRON UNITS 1 & 2 3.2.4 3 Amendment 238 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

(continued)

A.6

NOTE---------

Perform Required Action A.6 only after Required Action A.5 is completed.

Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after exceeding the THERMAL POWER limit of Required Action A.1 B.

Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to 50% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

QPTR 3.2.4 BYRON UNITS 1 & 2 3.2.4 4 Amendment 238 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1

NOTES--------------------

1.

With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER 75% RTP, the remaining three power range channel inputs can be used for calculating QPTR.

2.

SR 3.2.4.2 may be performed in lieu of this Surveillance.

Verify QPTR is within limit by calculation. In accordance with the Surveillance Frequency Control Program SR 3.2.4.2

NOTE--------------------

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after input from one Power Range Neutron Flux channel is inoperable with THERMAL POWER > 75% RTP.

Verify QPTR is within limit using the movable incore detectors.

In accordance with the Surveillance Frequency Control Program AND

NOTE----------------------------------

Only required to be performed if calibrated output of one Power Range Neutron Flux channel is unavailable, and THERMAL POWER > 75% RTP.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months following any rod motion 12 steps if an associated digital rod position indicator is inoperable using the movable incore detector system.

With the calibrated output of one Power Range Neutron Flux channel unavailable and THERMAL POWER 75% RTP, the remaining three Power Range Neutron Flux channels can be used to determine QPTR.

The movable incore detector system can be used to determine QPTR.

v t e Letter Sequence Request
EPID:L-2025-LLA-0194, (Open)
Initiation Request Acceptance Administration Withholding Request Acceptance Questions Answers Results Approval... Other:
MONTHYEAR2025-12-12 [Table View]

RS-25-153, Application to Adopt Changes to the Quadrant Power Tilt Ratio Technical Specification

Text

Subject:

Subject:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

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