RS-25-089, Additional Response to Request for Additional Information Related to License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, to Transition to Framatome Gaia Fuel and Exemptions to 10 CFR 50.46
| ML25121A230 | |
| Person / Time | |
|---|---|
| Site: | Braidwood, Byron  |
| Issue date: | 05/01/2025 |
| From: | Steinman R Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25121A229 | List: |
| References | |
| RS-25-089 | |
| Download: ML25121A230 (1) | |
Text
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 3 this document is decontrolled.
May 1, 2025 10 CFR 50.90 RS-25-089 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 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:
Additional Response to Request for Additional Information Related to License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, to Transition to Framatome GAIA Fuel and Exemptions to 10 CFR 50.46
Reference:
- 1. Letter from R. Steinman (Constellation Energy Generation, LLC) to U.S.
NRC, "License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, to transition to Framatome GAIA fuel and exemptions to 10 CFR 50.46 and 10 CFR 50 Appendix K", dated May 28, 2024 (ADAMS Accession No. ML24149A126) 2.
Letter from S. Wall (U.S. NRC) to D.Rhoades (Constellation Energy Generation, LLC), "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 - Request for Additional Information in Support of Review of License Amendment Request to Transition to Framatome GAIA Fuel (EPID L-2024-LLA-0072)" dated April 10, 2025 (ADAMS Accession No. ML25100A039)
In Reference 1, Constellation Energy Generation, LLC (CEG) requested an amendment to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood) and Renewed Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron). The proposed amendment is to change:
U.S. Nuclear Regulatory Commission 1, 2025 Page 2 TS 2.1.1, "Reactor Core SLs" to add limits for the GAIA fuel type.
TS 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))" to replace the Westinghouse FQ W(Z) with the Framatome FQ V(Z). Additionally, ACTIONS B is revised to remove REQUIRED ACTIONS B.1, B.3, and B.4.
TS 3.5.1, "Accumulators" to raise SR 3.5.1.4 and 3.5.1.5 ECCS boron limits.
TS 3.5.4, "Refueling Water Storage Tank (RWST)" to raise SR 3.5.4.4 ECCS boron limits.
TS 4.2.1, "Fuel Assemblies" to add M5Framatome fuel rod cladding.
TS 5.5.16, "Containment Leakage Rate Testing Program" to change Pa to 38.7 psig for Unit 2.
TS 5.6.5, "Core Operating Limits Report (COLR)" to add Framatome analytical methods to TS 5.6.5.b. Additionally, add LCO 3.1.4, 3.3.1, and 3.3.9 to TS 5.6.5.a.
In Reference 2, the NRC requested additional information that is needed to complete review of the license amendment request. In response to this request, CEG is providing the attached information.
Attachments 4 and 5 includes mark-ups of TS 5.6.5, "Core Operating Limits Report (COLR)". The additional changes are editorial in nature.
CEG has reviewed the information supporting the finding of No Significant Hazards Consideration, and the Environmental Consideration that were previously provided to the NRC.
The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
CEG is notifying the State of Illinois of this supplement to a previous application for a change to the operating license by sending a copy of this letter and its attachments to the designated State Official in accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"
paragraph (b).
There are no regulatory commitments included in this letter.
U.S. Nuclear Regulatory Commission
, 2025 Page 3 Should you have any questions concerning this letter, please contact Ms. Lisa Zurawski at 231-6196.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1st day of May 2025.
Respectfully, Rebecca L Steinman Sr. Manager Licensing Constellation Energy Generation, LLC Attachments:
1.
Response to Request for Additional Information (Non-Proprietary) 2.
Response to Request for Additional Information (Proprietary) 4.
Braidwood Mark-up of Technical Specification 5.6.5 5.
Byron Mark-up of Technical Specification 5.6.5 cc:
Regional Administrator - NRC Region III NRC Senior Resident Inspector - Byron Nuclear Power Station NRC Senior Resident Inspector - Braidwood Nuclear Power Station Illinois Emergency Management Agency - Department of Nuclear Safety
ATTACHMENT 1 BRAIDWOOD STATION UNITS 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 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 Docket Nos. STN-50-454 and STN-50-455 Response to Request for Additional Information
0414-12-F04 (Rev. 005, 04/10/2024)
Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report ANP-4149NP Revision 0 April 2025 (c) 2025 Framatome Inc.
ANP-4149NP Revision 0 0414-12-F04 (Rev. 005, 04/10/2024)
Copyright © 2025 Framatome Inc.
All Rights Reserved FRAMATOME TRADEMARKS ARCADIA, AREA, ARITA, ARTEMIS, GAIA and S-RELAP5 are trademarks or registered trademarks of Framatome or its affiliates, in the USA or other countries.
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page i Nature of Changes Item Section(s) or Page(s)
Description and Justification 1
All Initial Issue
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page ii Contents Page
1.0 INTRODUCTION
............................................................................................... 1-1 2.0 RAIS.................................................................................................................. 2-1 2.1 SFNB-RAI-1............................................................................................ 2-1 2.2 SFNB-RAI-2............................................................................................ 2-2 2.3 SFNB-RAI-3............................................................................................ 2-3 2.4 SFNB-RAI-4............................................................................................ 2-5 2.5 SFNB-RAI-5............................................................................................ 2-8 2.6 SFNB-RAI-6.......................................................................................... 2-11 2.7 SFNB-RAI-7.......................................................................................... 2-13 2.8 SFNB-RAI-8.......................................................................................... 2-14
3.0 REFERENCES
.................................................................................................. 3-1
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page iii List of Figures Figure 2-1 [
]................. 2-16
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page iv Nomenclature Acronym Definition AREA ARCADIA Rod Ejection Accident ARITA ARTEMIS/RELAP Integrated Transient Analysis EM Evaluation Model FOM Figure(s) of Merit GCN Global Core Neutronics LAR License Amendment Request MB-2 Model Boiler 2 MSLB Main Steamline Break Non-LOCA Non-Loss of Coolant Accident NRC United States (U.S.) Nuclear Regulatory Commission PCS Primary Coolant System RAI Request for Additional Information RBHT Rod Bundle Heat Transfer RCCA Rod Cluster Control Assembly RCS Reactor Coolant System RTP Rated Thermal Power RVUH Reactor Vessel Upper Head SEC Secondary Coolant System SG Steam Generator SLB Steam Line Break
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 1-1
1.0 INTRODUCTION
The purpose of this document is to provide responses to the Nuclear Regulatory Commission (NRC) Requests for Additional Information (RAI) in support of the non-Loss of Coolant Accident (Non-LOCA) event analyses using the ARTEMIS/RELAP Integrated Transient Analysis (ARITA) methodology (Reference 1) for the Byron/Braidwood GAIA fuel transition (Reference 2).
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-1 2.0 RAIS 2.1 SFNB-RAI-1 RAI Comment:
In audit meetings that took place from 2/24/2025 to 3/21/2025, the NRC staff discussed with the licensee several points regarding the method of adherence to ARITA Limitation and Condition 6, which requires, in the absence of pertinent plant-specific data or information, licensees [
]
With regard to this Limitation and Condition and the discussions that took place, please confirm the NRC staffs understanding of the following items:
For the GAIA fuel transition, the [
]
In response to this, [
]
The relevant [
] was not significant.
Response to SFNB-RAI-1:
Framatome confirms the NRCs understanding relative to Limitation and Condition 6 as described in SFNB-RAI-1.
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-2 2.2 SFNB-RAI-2 RAI Comment:
The justification provided in ANP-4087, Revision 1, regarding adherence to ARITA Limitation and Condition 8 discusses the [
] with respect to the coupled and static evaluation model variants. However, regarding the zero-dimensional evaluation model variant, [
] In audit meetings that took place from 2/24/2025 to 3/21/2025, the NRC staff discussed with the licensee several points regarding the method of adherence to Limitation and Condition 8.
Please confirm the NRC staffs understanding of the following items:
For the GAIA fuel transition, [
]
For future analyses that [
]
Response to SFNB-RAI-2:
Framatome confirms the NRCs understanding relative to Limitation and Condition 8 as described in SFNB-RAI-2.
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-3 2.3 SFNB-RAI-3 RAI Comment:
The justification provided in ANP-4087, Revision 1, regarding adherence to ARITA Limitation and Condition 9 discusses how [
]
Please provide a brief discussion of the analysis that was performed for the GAIA fuel transition LAR for demonstrating adherence to this Limitation and Condition. In this discussion, please include the magnitudes of [
]
Response to SFNB-RAI-3:
Reference 1, Limitation and Condition 9 specifies that, in the absence of additional data, the ARITA methodology shall justify that a [
]
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-4
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-5 2.4 SFNB-RAI-4 RAI Comment:
The justification provided in ANP-4087, Revision 1, regarding adherence to ARITA Limitation and Condition 11 discusses [
] This same comparison was provided in the ARITA topical report, ANP-10339P-A. While the results provided ANP-10339P-A demonstrate [
] which is conservative for a main steam line break event, the NRC staff has concerns with regard to the scaling applicability of the test facility to full-size [
] and the assurance that [
] will be conservatively predicted in future analyses for all relevant reactor designs. In particular, the scaling analysis report for the test facility indicates there are differences in the design of the [
]
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-6 In light of this, please provide a discussion on the scaling applicability of the [
] for the main steam line break event. In particular, please discuss [
]
Response to SFNB-RAI-4:
The remainder of the response is provided to specifically address the five specific questions in the second part of this RAI.
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-7
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-8 2.5 SFNB-RAI-5 RAI Comment:
The justifications provided in ANP-4087, Revision 1, regarding adherence to ARITA Limitation and Conditions 12 and 13 discuss the establishment of [
] In audit meetings that took place from 2/24/2025 to 3/21/2025, Framatome indicated that [
]
Please provide a brief description of the generation of [
]
the applicable lower pressure range, and the mean, standard deviation, and type of distribution. Additionally, please [
]
Response to SFNB-RAI-5:
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-9
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-10
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-11 2.6 SFNB-RAI-6 RAI Comment:
The justification provided in ANP-4087, Revision 1, regarding adherence to ARITA Limitation and Condition 15 discusses how justification will be established for the
[
] for any event that exhibits a prompt critical response. Please indicate the events that have been identified for the GAIA fuel transition LAR to exhibit a prompt critical response and provide a brief discussion of the analysis approach that was performed for these events. In this discussion, please include the magnitudes of [
] and identify the impact on pertinent figures of merit.
Response to SFNB-RAI-6:
Limitation and Condition 15 states that for any event that exhibits a prompt critical response, a justification must be provided for the [
]
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-12
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-13 2.7 SFNB-RAI-7 RAI Comment:
In audit meetings that took place from 2/24/2025 to 3/21/2025, the NRC staff noted several items regarding the basis for item 7 under Section 2.1.2, Methodology Departures of ANP-4087P. Please confirm the following items regarding Methodology Departure Item 7, which discusses evaluating [
]
ARTEMIS null transient calculations were performed in AREA and ARITA to evaluate the equivalence between the transient ARTEMIS model when applied with static core conditions and the static evaluation model.
The evaluation demonstrated that, [
]
Response to SFNB-RAI-7:
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-14 2.8 SFNB-RAI-8 RAI Comment:
Regarding Methodology Clarification 1a for ARITA in Section 2.1.3 of ANP-4087P, Revision 1, the charging and letdown system modeling, please further discuss [
]
Response to SFNB-RAI-8:
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-15
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 2-16 Figure 2-1
[
]
Framatome Inc.
ANP-4149NP Revision 0 Response to Request for Additional Information in Support of Byron and Braidwood License Amendment Request to Transition to Framatome GAIA Fuel Licensing Report Page 3-1
3.0 REFERENCES
- 1. ANP-10339P-A, Revision 0, ARITA - ARTEMIS/RELAP Integrated Transient Analysis Methodology.
- 2. ANP-4087P, Revision 1, Byron and Braidwood Non-LOCA Summary Report with ARITA Methodology.
- 3. [
]
- 4. [
]
- 5. ANP-10338P-A, Revision 0, AREA - ARCADIA Rod Ejection Accident.
ATTACHMENT 2 BRAIDWOOD STATION UNITS 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 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 Docket Nos. STN-50-454 and STN-50-455 Affidavit Framatome
ATTACHMENT 3 BRAIDWOOD STATION UNITS 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 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 Docket Nos. STN-50-454 and STN-50-455 Response to Request for Additional Information (Proprietary)
ATTACHMENT 4 BRAIDWOOD STATION UNITS 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 Docket Nos. STN-50-456 and STN-50-457 Mark-up of Technical Specification Pages
LCO 3.1.4, "Rod Group Alignment Limits";
LCO 3.3.1, "Reactor Trip System (RTS)
Instrumentation";
LCO 3.3.9, "Boron Dilution Protection System (BDPS)";
ATTACHMENT 5 BYRON STATION UNITS 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 Docket Nos. STN-50-454 and STN-50-455 Mark-up of Technical Specification Pages
LCO 3.1.4, "Rod Group Alignment Limits";
LCO 3.3.1, "Reactor Trip System (RTS)
Instrumentation";