Letter Sequence Response to RAI |
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MONTHYEARRS-21-077, License Amendment to Revise Technical Specification 3.7.9, Ultimate Heat Sink2021-08-0202 August 2021 License Amendment to Revise Technical Specification 3.7.9, Ultimate Heat Sink Project stage: Other ML21252A0172021-09-0303 September 2021 NRR E-mail Capture - NRC Acceptance Review - Braidwood - License Amendment to Revise Technical Specification 3.7.9, Ultimate Heat Sink Project stage: Acceptance Review ML21314A2182022-01-18018 January 2022 Audit Plan in Support of Review of License Amendment Request Regarding the Ultimate Heat Sink Project stage: Other RS-22-072, Response to Request for Additional Information Regarding License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2022-06-0606 June 2022 Response to Request for Additional Information Regarding License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink Project stage: Response to RAI BW230019, Steam Generator Eddy Current Inspection Report Refueling Outage 23 (A1R23) - October 20222022-10-31031 October 2022 Steam Generator Eddy Current Inspection Report Refueling Outage 23 (A1R23) - October 2022 Project stage: Request ML22314A2412022-12-16016 December 2022 Withdrawal of an Amendment Request - Letter - Project stage: Withdrawal ML22314A2502022-12-19019 December 2022 Withdrawal of an Amendment Request - FRN - Project stage: Withdrawal 2022-10-31
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Category:Letter type:RS
MONTHYEARRS-24-004, Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators2024-01-11011 January 2024 Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators RS-23-118, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information RS-23-114, Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds2023-11-0101 November 2023 Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans RS-23-108, Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles2023-10-11011 October 2023 Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles RS-23-105, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections2023-10-10010 October 2023 Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections RS-23-093, License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel.2023-09-29029 September 2023 License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel. RS-23-083, Withdrawal - Proposed Alternatives Related to the Steam Generators2023-06-27027 June 2023 Withdrawal - Proposed Alternatives Related to the Steam Generators RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations RS-23-074, Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-06-0909 June 2023 Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-075, Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process2023-06-0707 June 2023 Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process RS-23-050, Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube.2023-05-22022 May 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube. RS-23-056, Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 102023-04-20020 April 2023 Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 10 RS-23-055, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors2023-04-10010 April 2023 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors RS-23-052, License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-03-24024 March 2023 License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations RS-23-045, Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.2032023-02-28028 February 2023 Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.203 RS-23-040, Constellation Energy Generation, LLC, Supplemental Information - Proposed Alternatives Related to the Steam Generators2023-02-21021 February 2023 Constellation Energy Generation, LLC, Supplemental Information - Proposed Alternatives Related to the Steam Generators RS-23-003, Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-102023-01-31031 January 2023 Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-10 RS-22-123, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator2022-12-0707 December 2022 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator RS-22-126, Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2022-11-30030 November 2022 Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI RS-22-118, Withdrawal of License Amendment Request to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2022-10-31031 October 2022 Withdrawal of License Amendment Request to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-22-110, Supplemental Information - Proposed Alternatives Related to the Steam Generators and Request.2022-09-20020 September 2022 Supplemental Information - Proposed Alternatives Related to the Steam Generators and Request. RS-22-093, Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans2022-08-18018 August 2022 Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans RS-22-086, R. E. Ginna Nuclear Power Plant - Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam.2022-08-10010 August 2022 R. E. Ginna Nuclear Power Plant - Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam. RS-22-084, Response to Request for Additional Information Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator .2022-06-17017 June 2022 Response to Request for Additional Information Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator . RS-22-072, Response to Request for Additional Information Regarding License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2022-06-0606 June 2022 Response to Request for Additional Information Regarding License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-22-075, License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2022-06-0202 June 2022 License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-22-074, Response to Request for Additional Information - Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds .2022-05-20020 May 2022 Response to Request for Additional Information - Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds . RS-22-073, Supplemental Information Regarding License Amendment Request -Adoption of Technical Specification Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube.2022-05-19019 May 2022 Supplemental Information Regarding License Amendment Request -Adoption of Technical Specification Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube. RS-22-037, License Amendment Request - Adoption of Technical Specification Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control2022-04-21021 April 2022 License Amendment Request - Adoption of Technical Specification Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control RS-22-051, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-04-12012 April 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-047, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors2022-04-0808 April 2022 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors RS-22-050, Supplemental Information - Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds2022-04-0808 April 2022 Supplemental Information - Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds RS-22-049, Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for2022-04-0404 April 2022 Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for V RS-22-045, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-25025 March 2022 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations RS-22-014, Application to Adopt TSTF-246, RTS Instrumentation, 3.3.1 Condition F Completion Time2022-03-24024 March 2022 Application to Adopt TSTF-246, RTS Instrumentation, 3.3.1 Condition F Completion Time RS-22-041, Withdrawal of License Amendment Request to Revise Technical Specifications 5.6.5, Core Operating Limits Report (COLR) to Add References to NRC Approved Topical Report with Administrative Changes2022-03-22022 March 2022 Withdrawal of License Amendment Request to Revise Technical Specifications 5.6.5, Core Operating Limits Report (COLR) to Add References to NRC Approved Topical Report with Administrative Changes RS-22-036, Supplemental Information - Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds2022-03-10010 March 2022 Supplemental Information - Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds RS-22-023, Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement2022-02-23023 February 2022 Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P RS-22-019, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-02-16016 February 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-015, Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC2022-02-0101 February 2022 Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC RS-22-008, Application to Revise Technical Specifications 5.6.5, Core Operating Limits Report to Add References to NRC-Approved Topical Report with Admin2022-01-24024 January 2022 Application to Revise Technical Specifications 5.6.5, Core Operating Limits Report to Add References to NRC-Approved Topical Report with Admin RS-22-004, Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2022-01-0404 January 2022 Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RS-21-121, Proposed Changes to Decommissioning Trust Agreements and Master Terms2021-12-15015 December 2021 Proposed Changes to Decommissioning Trust Agreements and Master Terms RS-21-117, Application for Amendment to Renewed Facility License to Remove License Condition 2.C.(12)(d)2021-12-0909 December 2021 Application for Amendment to Renewed Facility License to Remove License Condition 2.C.(12)(d) RS-21-112, Updated 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors2021-10-22022 October 2021 Updated 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors RS-21-091, Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes2021-09-13013 September 2021 Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes RS-21-093, R. E. Ginna, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections2021-09-0101 September 2021 R. E. Ginna, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections 2024-01-11
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARRS-23-118, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information RS-23-056, Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 102023-04-20020 April 2023 Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 10 RS-22-123, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator2022-12-0707 December 2022 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator RS-22-084, Response to Request for Additional Information Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator .2022-06-17017 June 2022 Response to Request for Additional Information Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator . RS-22-072, Response to Request for Additional Information Regarding License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2022-06-0606 June 2022 Response to Request for Additional Information Regarding License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-22-074, Response to Request for Additional Information - Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds .2022-05-20020 May 2022 Response to Request for Additional Information - Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds . RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P ML21320A2422021-11-16016 November 2021 Stations - Response to Request for Additional Information - Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds JAFP-21-0087, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-09-16016 September 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments ML21225A0062021-08-13013 August 2021 Response to Request for Additional Information Regarding License Amendment Request to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0 NMP2L2773, Company - Response to Request for Additional Information2021-06-30030 June 2021 Company - Response to Request for Additional Information JAFP-21-0044, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-06-11011 June 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments JAFP-21-0032, Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting2021-04-20020 April 2021 Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting RS-21-015, Response to Request for Additional Information Related to Relief Request for Braidwood I4R-11 and Byron I4R-182021-02-10010 February 2021 Response to Request for Additional Information Related to Relief Request for Braidwood I4R-11 and Byron I4R-18 RS-21-019, Response to Request for Additional Information Regarding Application for Revision to TS 5.5.9, Steam Generator (SG) Program, for a One-Time Deferral of Steam Generator Tube Inspections2021-02-0909 February 2021 Response to Request for Additional Information Regarding Application for Revision to TS 5.5.9, Steam Generator (SG) Program, for a One-Time Deferral of Steam Generator Tube Inspections RS-20-017, Response to Request for Additional Information - Proposed Alternative to Utilize Code Case N-8852021-02-0101 February 2021 Response to Request for Additional Information - Proposed Alternative to Utilize Code Case N-885 RS-20-147, Response to Request for Additional Information Related to Exemption from Part 26 Requirements2020-11-23023 November 2020 Response to Request for Additional Information Related to Exemption from Part 26 Requirements RS-20-143, Response to Request for Additional Information Regarding Application to Revise Technical Specifications 3.8.1, AC Sources- Operating2020-11-20020 November 2020 Response to Request for Additional Information Regarding Application to Revise Technical Specifications 3.8.1, AC Sources- Operating ML20188A2642020-07-0606 July 2020 Clinton Power Station, R.E. Ginna Station, Limerick Station, Nine Mile Point Station & Peach Bottom Station - Proposed Alternative to Utilize Code Case OMN-26 - Response to Request for Additional Information RS-20-057, Response to Request for Additional Information Regarding Emergency License Amendment Request for a One-Time Extension of the Steam Generator Tube Inspections2020-04-13013 April 2020 Response to Request for Additional Information Regarding Emergency License Amendment Request for a One-Time Extension of the Steam Generator Tube Inspections RS-20-012, Response to Request for Additional Information Regarding Relief Request Associated with the Third Ten-Year Inservice Inspection Program Interval2020-01-29029 January 2020 Response to Request for Additional Information Regarding Relief Request Associated with the Third Ten-Year Inservice Inspection Program Interval NMP2L2711, Byron Station; Calvert Cliffs; Clinton Power Station; LaSalle County Station; Limerick Generating Station; and Nine Mile Point Nuclear Station - Proposed Alternative to Utilize Code Case N-8792019-10-16016 October 2019 Byron Station; Calvert Cliffs; Clinton Power Station; LaSalle County Station; Limerick Generating Station; and Nine Mile Point Nuclear Station - Proposed Alternative to Utilize Code Case N-879 RS-19-100, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended.2019-10-0707 October 2019 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended. RS-19-088, Response to Request for Additional Information Regarding Application to Revise Braidwood Station and Byron Station Technical Specifications to Adopt Risk Informed...2019-09-0505 September 2019 Response to Request for Additional Information Regarding Application to Revise Braidwood Station and Byron Station Technical Specifications to Adopt Risk Informed... JAFP-19-0057, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-06-0404 June 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 RS-19-051, Response to Request for Additional Information for the License Amendment Request to Utilize Tvel TVS-K Lead Test Assemblies2019-05-30030 May 2019 Response to Request for Additional Information for the License Amendment Request to Utilize Tvel TVS-K Lead Test Assemblies NMP1L3279, Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants2019-05-0101 May 2019 Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants JAFP-19-0006, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-01-0808 January 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 RS-18-143, Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements2018-11-29029 November 2018 Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements RS-18-094, Response to Request for Additional Information Regarding Braidwood Station Fourth Lnservice Inspection Interval Relief Request 14R-062018-07-31031 July 2018 Response to Request for Additional Information Regarding Braidwood Station Fourth Lnservice Inspection Interval Relief Request 14R-06 RS-18-095, Response to Request for Additional Information Regarding Braidwood Station Fourth Lnservice Inspection Interval Relief Request 14R-032018-07-31031 July 2018 Response to Request for Additional Information Regarding Braidwood Station Fourth Lnservice Inspection Interval Relief Request 14R-03 RS-18-097, Response to Request for Additional Information and Supplemental Information-License Amendment.2018-07-27027 July 2018 Response to Request for Additional Information and Supplemental Information-License Amendment. RS-18-084, Response to Request for Additional Information Regarding Braidwood TORMIS Amendment Request2018-07-0909 July 2018 Response to Request for Additional Information Regarding Braidwood TORMIS Amendment Request RS-18-083, Response to Request for Additional Information Regarding Braidwood Station Fourth Inservice Inspection Interval Relief Request 14R-052018-06-22022 June 2018 Response to Request for Additional Information Regarding Braidwood Station Fourth Inservice Inspection Interval Relief Request 14R-05 RS-18-072, Response to Request for Additional Information Regarding 50.69 Amendment2018-06-13013 June 2018 Response to Request for Additional Information Regarding 50.69 Amendment RS-18-061, Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)2018-05-0202 May 2018 Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis) RS-18-041, Response to Request for Additional Information Regarding Request for Relief (I4R-07) for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened ...2018-04-12012 April 2018 Response to Request for Additional Information Regarding Request for Relief (I4R-07) for Extension of Examination Interval for Reactor Pressure Vessel Head Penetration Nozzles with Mitigated Alloy 600/82/182 Peened ... RS-17-138, Stations - Response to Request for Additional Information Related to License Amendment Request to Incorporate Changes Supported by TSTF-547, Clarification of Rod Position Requirements'2017-10-25025 October 2017 Stations - Response to Request for Additional Information Related to License Amendment Request to Incorporate Changes Supported by TSTF-547, Clarification of Rod Position Requirements' RS-17-084, Response to Request for Additional Information for Byron Station and Braidwood Station Post Peening Relief Requests2017-07-14014 July 2017 Response to Request for Additional Information for Byron Station and Braidwood Station Post Peening Relief Requests RS-17-085, Response to Request for Additional Information Regarding Amendments to Remove Obsolete License and Technical Specification Items2017-06-29029 June 2017 Response to Request for Additional Information Regarding Amendments to Remove Obsolete License and Technical Specification Items ML17178A0762017-06-26026 June 2017 Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 15; Supplemental Information Letter RS-17-044, Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography2017-03-13013 March 2017 Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography RS-16-213, Response to Request for Additional Information Regarding Relief Request 13R-17 to Extend the Reactor Pressure Vessel Inservice Inspection Interval2016-11-21021 November 2016 Response to Request for Additional Information Regarding Relief Request 13R-17 to Extend the Reactor Pressure Vessel Inservice Inspection Interval RS-16-231, Revised Response to Request for Additional Information for License Amendment Request for a One-Time Extension of the Essential Service Water (SX) Train Completion Time to Support 2A SX Pump Repair2016-11-14014 November 2016 Revised Response to Request for Additional Information for License Amendment Request for a One-Time Extension of the Essential Service Water (SX) Train Completion Time to Support 2A SX Pump Repair RS-16-222, Response to Request for Additional Information Related to License Amendment Request for a One-Time Extension of the Essential Service Water (SX) Train Completion Time to Support 2A SX Pump Repair2016-10-28028 October 2016 Response to Request for Additional Information Related to License Amendment Request for a One-Time Extension of the Essential Service Water (SX) Train Completion Time to Support 2A SX Pump Repair RS-16-218, Response to Request for Additional Information License Amendment Request for a One-Time Extension of the Essential Service Water Train Completion Time to Support 2A SX Pump Repair2016-10-26026 October 2016 Response to Request for Additional Information License Amendment Request for a One-Time Extension of the Essential Service Water Train Completion Time to Support 2A SX Pump Repair RA-16-049, Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure2016-05-26026 May 2016 Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure RS-16-112, Response to Request for Additional Information Regarding Request for a License Amendment to Technical Specification 3.7.9, Ultimate Heat Sink.2016-04-29029 April 2016 Response to Request for Additional Information Regarding Request for a License Amendment to Technical Specification 3.7.9, Ultimate Heat Sink. RS-16-079, Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50.55a, Codes and Standards, Paragraph (h)(2), Protection Systems, Including Change to Request NRC Approval Under 10 CFR 50.55a..2016-04-11011 April 2016 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50.55a, Codes and Standards, Paragraph (h)(2), Protection Systems, Including Change to Request NRC Approval Under 10 CFR 50.55a.. RS-16-078, Clarification to Response to Requests for Additional Information for Relief for Alternate Requirements for Repair of Reactor Vessel Head Penetrations with Nozzles Having Pressure-Retaining Partial-Penetration J-Groove Welds2016-04-0404 April 2016 Clarification to Response to Requests for Additional Information for Relief for Alternate Requirements for Repair of Reactor Vessel Head Penetrations with Nozzles Having Pressure-Retaining Partial-Penetration J-Groove Welds 2023-04-20
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Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-22-072 10 CFR 50.90 June 6, 2022 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
Subject:
Response to Request for Additional Information Regarding License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, "Ultimate Heat Sink"
References:
- 1) Letter from D. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, " License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, "Ultimate Heat Sink"," dated August 2, 2021 (ADAMS Package Accession No. ML21214A331).
- 2) Email from J. Wiebe (U.S. Nuclear Regulatory Commission) to P. A.
Henderson (Constellation Energy Generation, LLC), "Request for Additional Information Regarding Braidwood, Units 1 and 2, Amendment Request for Technical Specification 3.7.9, "Ultimate Heat Sink," dated March 29, 2022.
By application dated August 2, 2021 (Reference 1), Exelon Generation Company, LLC (EGC) requested an amendment to the Technical Specifications (TS) for Renewed Facility License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood). On February 1, 2022 the NRC approved the license transfer of the above facilities to Constellation Energy Generation, LLC, (CEG). The proposed amendment adds two Required Actions and associated Completion Times to Technical Specification (TS) 3.7.9, "Ultimate Heat Sink," for an inoperable Ultimate Heat Sink (UHS) due to the average water temperature.
The proposed amendment also revises TS 3.7.9 Surveillance Requirement (SR) 3.7.9.2 to delete the temporary allowance for the UHS average water temperature of 102.8°F until September 30, 2021. This temporary change to the SR was implemented by Amendment No.
222 to Renewed Facility Operating License No. NPF-72 and Amendment No. 222 to Renewed Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, respectively, as documented in NRC Safety Evaluation Report (SER) dated July 13, 2021. (ADAMS Access No.
ML21154A046). This is an administrative change.
June 6, 2022 U.S. Nuclear Regulatory Commission Page 2 In NRC email dated March 29, 2022 (Reference 2), the NRC determined that additional information is needed to complete its review. The Attachment to this letter provides the requested information.
CEG has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously provided to the NRC in Attachment 1 of the Reference 1 letter. The additional information provided in this submittal does not affect the conclusion that the proposed license amendment does not involve a significant hazards consideration. This additional information also does not affect the conclusion that there is no need for an environmental assessment to be prepared in support of the proposed amendment.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),
CEG is providing a copy of this letter and its attachment to the State of Illinois.
This letter contains no regulatory commitments. Should you have any questions concerning this submittal, please contact Mr. Phillip A. Henderson at (630) 657-4727.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of June 2022.
Respectfully, Lueshen, Digitally signed by Lueshen, Kevin Kevin Date: 2022.06.06 12:06:37 -05'00' Kevin Lueshen Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments:
1 Response to Request for Additional Information 2 Markup of Technical Specifications Pages cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector - Braidwood Station Illinois Emergency Management Agency - Division of Nuclear Safety
ATTACHMENT 1 Response to Request for Additional Information By application dated August 2, 2021 (Reference 1), Exelon Generation Company, LLC (EGC) requested an amendment to the Technical Specifications (TS) for Renewed Facility License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood). On February 1, 2022 the NRC approved the license transfer of the above facilities to Constellation Energy Generation, LLC, (CEG). The proposed amendment adds two Required Actions and associated Completion Times to Technical Specification (TS) 3.7.9, "Ultimate Heat Sink," for an inoperable Ultimate Heat Sink (UHS) due to the average water temperature.
The proposed amendment also revises TS 3.7.9 Surveillance Requirement (SR) 3.7.9.2 to delete the temporary allowance for the UHS average water temperature of 102.8°F until September 30, 2021. This temporary change to the SR was implemented by Amendment No.
222 to Renewed Facility Operating License No. NPF-72 and Amendment No. 222 to Renewed Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, respectively, as documented in NRC Safety Evaluation Report (SER) dated July 13, 2021. (ADAMS Access No.
ML21154A046). This is an administrative change.
In NRC email dated March 29, 2022 (Reference 2), the NRC determined that additional information is needed to complete its review. The Attachment to this letter provides the requested information.
References:
- 1) Letter from D. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, " License Amendment to Revise Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, "Ultimate Heat Sink"," dated August 2, 2021 (ADAMS Package Accession No. ML21214A331).
- 2) Email from J. Wiebe (U.S. Nuclear Regulatory Commission) to P. A. Henderson (Constellation Energy Generation, LLC), "Request for Additional Information Regarding Braidwood, Units 1 and 2, Amendment Request for Technical Specification 3.7.9, "Ultimate Heat Sink," dated March 29, 2022.
- 3) NUREG-1431, Standard Technical Specifications, Westinghouse Plant, Volume 1, Revision 5, dated September 2021.
NRC RAI A The proposed changes to LCO 3.7.9 potentially allows indefinite operation above the currently approved UHS average temperature limit of 102°F. An example of how this could occur is if the average UHS temperature remains above 102°F and very briefly falls below 102°F overnight due to diurnal cooling effects. At the time when the average UHS temperature falls below 102°F, the LCO would be exited and then reentered shortly thereafter as the temperature increased back above 102°F. This cycle could be repeated indefinitely. Given this situation, the UHS temperature limit would effectively be the maximum analyzed temperature which would be contained in a licensee-controlled document. In addition to being located in a licensee-controlled document, based on discussions during the regulatory audit on January 28, 2022, the calculations to determine the maximum analyzed temperature are not based on an NRC approved methodology.
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ATTACHMENT 1 Response to Request for Additional Information 10 CFR 50.36(b) states in part The technical specifications will be derived from the analyses and evaluation included in the safety analysis report. The final policy statement on TS (58 FR 39132) states The purpose of Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval. By moving the UHS maximum allowable temperature to a licensee-controlled document, this would allow changes to the conditions of operation without NRC approval.
NRC staff requests the licensee to explain how the proposed changes to LCO 3.7.9 meets the requirements and intent of 10 CFR 50.36.
The NRC staff notes that it has previously approved one way to meet the requirements and intent of 50.36 (ADAMS Accession No. ML21154A046), which proposed verification that the UHS was less than or equal to the actual maximum analyzed temperature value in SR 3.7.9.2 and provided a summary of the calculations used in determination of this value including a detailed description of all assumptions used.
CEG Response to NRC RAI A The maximum analyzed temperature will be determined following the same method discussed in ADAMS Accession No. ML21154A046 (NRC SER for 102.8 °F). As discussed in the Request for Additional Information, this method is acceptable to the NRC.
The Braidwood Ultimate Heat Sink maximum analyzed temperature does have a limiting value which is controlled by the Braidwood Technical Specifications.
Braidwood Technical Specifications (TS) Section 5.5.16 (Under Administrative Controls, Section 5), Containment Leakage Rate Testing Program:, lists the peak calculated containment internal pressure (Pa) values for the design basis Loss of Coolant Accident (LOCA), 42.8 psig for Unit 1 and 38.4 psig for Unit 2. The Braidwood design basis analysis for maximum internal pressure post-LOCA uses the heat removal rates for the Reactor Containment Fan Coolers (RCFCs) based on a cooling water temperature of 104 °F from the UHS.
Therefore, up to a UHS temperature of 104 °F, compliance is maintained with the TS purpose as stated in the final policy statement on Technical Specifications.
Increasing the UHS temperature above 104 °F would results in higher calculated Containment internal pressure. Increasing the peak calculated Containment internal pressure above the values in TS 5.5.16 requires NRC approval.
Moving the maximum UHS allowable temperature to licensee documents does not result in changes to conditions of operation imposed by the Technical Specifications without NRC Approval.
The time period permitted to exceed TS 3.7.9 UHS temperature limit of 102 °F is limited by a Completion Time of 7 days. For this time period, the results of the Design Basis Analysis for peak calculated Containment internal pressure are maintained up to a UHS temperature of 104 °F. Compliance with TS 5.5.16 is maintained.
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ATTACHMENT 1 Response to Request for Additional Information The short time period with UHS temperature above 102 °F does not create the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
Engineering judgement is used for other analysis that use the initial UHS temperature as input.
These analyses do not result in consequences that give rise to an immediate threat to the public health and safety. Although some of the inputs in these analyses may change, Engineering Judgment is used to conclude that the results are not adverse. These analyses are reviewed as part of the method discussed in ADAMS Accession No. ML21154A046 (NRC SER for 102.8 °F).
During the long-term response to a large break LOCA, when the Emergency Core Cooling System is drawing water from the containment recirculation sump, the UHS temperature can have an effect on fuel cladding temperatures. As documented in ADAMS Accession No. ML21154A046 (NRC SER for 102.8 °F, July 13, 2021) the fuel Peak Clad Temperature is not challenged by the increase in UHS temperature.
NRC RAI B It appears that Required Action A.1.2 is intended to limit the time the UHS temperature is above the currently approved UHS temperature limit of 102°F and below the maximum analyzed temperature to 7 days. However, as discussed above in RAI A, if the Condition were exited overnight given the diurnal cooling and then reentered the next day, the 7 days would be irrelevant as the completion time clock would reset. This is inconsistent with the intent of the Use and Application rules as stated in Section 1.3 of the Braidwood TS.
Braidwood TS Section 1.3 states:
It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely doing so would be inconsistent with the basis of the Completion Times.
Therefore, there shall be administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately extended.
NRC staff requests the licensee to:
a) provide details of any administrative controls that would allow the 7 days completion time to remain in effect if the overnight temperature of the UHS falls below 102°F, and b) provide the technical basis for A.1.2 which allows operation to continue at UHS temperatures above the currently approved limit of 102°F for 7 days.
CEG Response to NRC RAI B(a)
Constellation Energy Generation (CEG) currently operates Braidwood under the current TSs based which are based on NUREG-1431 (Reference 3). The NRC approved the adoption of TSTF-439, Eliminate Second Completion Times Limiting Time Frame from Discovery of Failure to Meet an LCO, Revision 2, with Amendment Nos. 203 issued to Braidwood, Units 1 and 2, dated October 8, 2019 (ML19266A527). Consistent with TSTF-439, the approved change: (1)
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ATTACHMENT 1 Response to Request for Additional Information modified Braidwood Technical Specifications Completion Times Example 1.3-3 to eliminate the second Completion Times contained within and revised the discussion in the Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis of the Completion Times and is inappropriate, and (2) removed second Completion Times contained in the TS.
Under the same methodology of the approved license amendment, CEG added a requirement to Section 1.3 of TS to require administrative controls to limit the maximum time allowed for any combination of conditions that result in a single contiguous occurrence of failing to meet the LCO.
CEG implemented a procedure revision to fleet procedure OP-AA-108-104, Tech Specification Compliance, Revision 3 to implement the requirements contained in TSTF-439 that applies to all TS Completion Times. The revision was approved for implementation on November 14, 2019 and added section 2.8 "LCO Completion Time"; which, adds wording similar to TS 1.3.
Operations currently monitors the Ultimate Heat Sink (UHS) temperature by averaging the running Essential Service Water (SX) pump discharge temperatures. This temperature is recorded twice per day in the Shiftly And Daily Operating Surveillance when in Modes 1-4 (1/2BwOSR 0.1-1,2,3 for Modes 1, 2, and 3, and 1/2BwOSR 0.1-4 for Mode 4). When the UHS temperature is >99.0 ºF operations measures the UHS temperature locally at a spare thermowell using precision instrumentation. In addition, the LCO 3.7.9 Tech Spec Conditions and Required Actions are controlled in administrative procedure 1/2BwOL 3.7.9, "LCOAR Ultimate Heat Sink (UHS) Tech Spec LCO 3.7.9.
Applicable Shiftly And Daily Operating Surveillances and administrative procedures will be revised to include local precision instrument monitoring once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when the UHS temperature is >102 ºF. The maximum analyzed UHS temperature limit will be documented in the procedures 1/2BwOSR 0.1-1,2,3, for Modes 1, 2, and 3, 1/2BwOSR 0.1-4, for Mode 4, and 1/2BwOL 3.7.9 for use by Operations.
In addition to the aforementioned changes, CEG will include the information for the Engineering Change as a reference to the procedures and the maximum analyzed temperature that has been evaluated for the initial implementation. Following implementation and prior to periods where the UHS average temperature may be challenged a review will be conducted to determine if the Engineering Change or procedures need to be revised from the previous implementation to update the maximum analyzed temperature.
In summary, the administrative controls imposed by CEG will increase the monitoring of the UHS average temperature to ensure that the maximum analyzed temperature will be met during the period when the UHS temperature exceeds the LCO limit. The time period that is allowed to exceed TS 3.7.9 UHS temperature limit of 102 °F is limited to 7 days. For this time period, the results of the Design Basis Analysis for peak calculated Containment internal pressure are maintained up to a UHS temperature of 104 °F. Compliance with TS 5.5.16 is maintained.
CEG Response to NRC RAI B(b)
In accordance with the proposed TS markups provided in Attachment 2, Required Action A.1.2 has been revised to Required Action A.2.
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ATTACHMENT 1 Response to Request for Additional Information The Braidwood Ultimate Heat Sink maximum analyzed temperature does have a limiting value which is controlled by the Braidwood Technical Specifications as discussed in the response to RAI A above. Therefore, up to a UHS temperature of 104 °F, compliance is maintained with the TS purpose as stated in the final policy statement on Technical Specifications.
The time period that is allowed to exceed TS 3.7.9 UHS temperature limit of 102 °F is limited to 7 days. During this time period, the results of the Design Basis Analysis for peak calculated Containment internal pressure are maintained up to a UHS temperature of 104 °F. Compliance with TS 5.5.16 is maintained.
The time period when the UHS temperature is above 102 °F does not create the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety because all of the applicable analyses and evaluations wills continue to be met.
Increasing the UHS temperature above 104 °F would result in a higher calculated Containment internal pressure. Increasing the peak calculated Containment internal pressure above the values in TS 5.5.16 requires NRC approval.
Braidwood could operate with the UHS temperature up to 104 ºF indefinitely given that the other system parameters are maintained within their current operating limits. The most restrictive limit is the RCFC cooling water temperature of 104 ºF. Required Action A.2 verifies the margins to those contained in the design basis analyses and evaluations within 7 days to ensure that the risk associated with exceeding the SR 3.7.9.2 limit for average UHS temperature is appropriately managed during the short period of time. Past historical temperature trending of the UHS provides reasonable assurance that a prolonged period of higher temperatures will not exceed a period of 7 days.
If the water temperature of the UHS exceeds the limits of the maximum analyzed temperature or 7 days, Condition B must be entered immediately, requiring entry into MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and entry into MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
NRC RAI C Regulatory Guide (RG) 1.27, Ultimate Heat Sink for Nuclear Power Plants, Revision 2, dated January 1976, provides an acceptable approach for satisfying General Design Criteria 2 and 44.
The application indicates that the UHS design analysis methodology is based on RG 1.27, Revision 2, and NUREG-0693, Analysis of Ultimate Heat Sink Cooling Ponds, dated November 1980.
RG 1.27 C.1.b states, Sufficient conservatism should be provided to ensure that a 30 day cooling supply is available and that design-basis temperatures of equipment that is important to safety are not exceeded. For UHSs where the water supply may be limited or the temperature of plant intake water from the UHS eventually may become critical (e.g., ponds, lakes, cooling towers, or other UHSs where recirculation between plant cooling water discharge and intake can occur), transient analyses of supply and/or temperature, as appropriate, should be performed. The transient analysis for the effluent from one unit affecting the performance of an adjacent unit should also be considered, for both normal operation and accident conditions.
The analysis should account for all variations of design parameters and the full range of operating conditions that may exist at the time of the postulated event. This type of analysis is commonly accomplished when the most severe set of operating parameters and/or operational Page 5 of 7
ATTACHMENT 1 Response to Request for Additional Information conditions is assumed to occur simultaneously and is commonly referred to as a bounding analysis. Alternatives to this approach should be communicated to the NRC staff for review.
The current TS temperature limit is based on the conclusion of the bounding analysis for UHS average water temperature less than 102°F. As indicated in RG 1.27, the analysis should account for all variations of design parameters and the full range of operating conditions that may exist at the time of the postulated event. With the proposed TS use of an undefined maximum analyzed temperature limit, there is no identified current bounding value.
a) Please describe how the maximum analyzed temperature limit will be defined and how the methodology accounts for all variations of design parameters and the full range of operating conditions that may exist at the time of the postulated event.
b) Please clarify the method that alternatives to this approach will be communicated to the NRC staff for review, as indicated in RG 1.27.
CEG Response to NRC RAI C The determination of the maximum analyzed temperature does not change inputs to the UHS Design Basis analysis. The limiting case from the DBA has been run with a UHS starting temperature of 104 °F to confirm the assumptions for the post-accident UHS temperature are supported:
- RCFC Heat removal with SX temperature of 104 °F. The maximum containment pressure and temperature occur early in the event, well before the UHS temperature increases above 104 °F.
- The maximum post accident UHS temperature remains below 106 °F. The post-accident performance of the equipment served by SX has been analyzed for a supply SX temperature of 106°F.
The maximum analyzed temperature will be determined following the same method discussed in ADAMS Accession No. ML21154A046 (SER for 102.8 °F in 2021).
The maximum analyzed temperature will be limited to 104 °F as discussed in RAI A.
NRC RAI D The use of the OR statement in the construct of the proposed TS could lead to confusion on what action should be taken if the Required Actions of A.1.1 and A.1.2 are not met in their Completion Times (would the facility enter LCO 3.0.3 or A.2.1 and A.2.2?).
Clarify the intent of the OR statement and whether moving the proposed Required Actions A.2.1 and A.2.2 to a new Condition B to be entered if the Required Actions and Completion Times of Condition A are not met would meet the intent of the proposed TS.
CEG Response to NRC RAI D Page 6 of 7
ATTACHMENT 1 Response to Request for Additional Information The Technical Specification (TS) markup included with the original submittal (Reference 1) was prepared with the intent that if Required Actions A.1.1 and A.1.2 could not be completed in their associated Completion Times, that Required Actions A.2.1 and A.2.2 would be implemented.
To alleviate any confusion and to maintain the same intent as the initial TS markup, a revised TS markup is provided in Attachment 2 of this document. In the revised TS markup, Condition B was added, which states "Required Action and associated Completion Time of Condition A not met ". Required Actions A.1.1 and A.1.2 are now A.1 and A.2, respectively, and Required Actions A.2.1 and A.2.2 are now B.1 and B.2 respectively. The TS markup provided in supersedes the previous TS markup provided in Reference 1.
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ATTACHMENT 2 BRAIDWOOD STATION UNITS 1 and 2 Renewed Facility Operting License Nos. NPF-72 and NPF-77 Docket Nos. STN-50-456 and STN-50-457 Markup of Technical Specifications Pages 3.7.9-1 3.7.9-2
3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)
LCO 3.7.9 The UHS shall be OPERABLE.
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. UHS inoperable due to A.1 Verify UHS average Immediately average water water temperature at temperature. or below the maximum analyzed temperature limit.
AND Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> thereafter AND A.2 Verify UHS average 7 days water temperature within limit.
B. Required Action and B.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A AND not met.
B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C. UHS inoperable for C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> reasons other than Condition A. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> BRAIDWOOD UNITS 1 & 2 3.7.9 1 Amendment 222
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level of UHS is 590 ft Mean In accordance Sea Level (MSL). with the Surveillance Frequency Control Program SR 3.7.9.2 Verify average water temperature of UHS is In accordance 102.8ºF until September 30, 2021. After with the September 30, 2021, verify average water Surveillance temperature of UHS is 102F. Frequency Control Program SR 3.7.9.3 Verify UHS contains a water volume of In accordance 555.8 acre-feet with the Surveillance Frequency Control Program BRAIDWOOD UNITS 1 & 2 3.7.9 2 Amendment 218