ML22214A004

Audit Plan to Support the Review of Amendments to Revise Criticality Safety Analysis Methodologies (Epids L-2022-LLA-0085, L-2021-LLA-0124, and L-2021-LLA-0159)

ML22214A004
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	08/02/2022
From:	Robert Kuntz Plant Licensing Branch III
To:	Rhoades D Constellation Energy Generation
Purnell B
References
EPID L 2021 LLA 0159, EPID L-2021-LLA-0124, EPID L-2022-LLA-0085
Download: ML22214A004 (6)

Text

August 2, 2022 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 6055

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, LASALLE COUNTY STATION, UNITS 1 AND 2, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - AUDIT PLAN TO SUPPORT THE REVIEW OF AMENDMENTS TO REVISE CRITICALITY SAFETY ANALYSIS METHODOLOGIES (EPIDS L-2022-LLA-0085, L-2021-LLA-0124, AND L-2021-LLA-0159)

Dear Mr. Rhoades:

By application dated June 8, 2022 (Agencywide Document Access and Management System (ADAMS) Accession No. ML22159A310) Constellation Energy Generation, LLC (Constellation) submitted a license amendment request (LAR) for Dresden Nuclear Power Station, Units 2 and 3 (Dresden). By application dated June 30, 2021 (ML21183A169), as supplement by letters dated November 4, 2021 (ML21312A457) and June 17, 2022 (ML22172A175) and application dated October 25, 2021 (ML21298A168), as supplemented by letter dated November 3, 2021 (ML22194A086), Exelon Generation Company, LLC, submitted LARs for LaSalle County Station, Units 1 and 2 (LaSalle), and Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities) respectively. On February 1, 2022 (ML22032A333), Exelon Generation Company, LLC was renamed Constellation. The amendments request the use of new criticality safety analysis (CSA) methodology for performing criticality safety evaluations for fuel in the spent fuel pool.

The U.S. Nuclear Regulatory Commission (NRC) staff will conduct a regulatory audit to support its review of all three LARs in accordance with the enclosed audit plan. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information.

The audit will be conducted to increase the NRC staffs understanding of the criticality methodology, and to identify information that will require docketing to support the NRC staffs regulatory findings. The audit will be conducted from August 4, 2022, through September 2, 2022, primarily in a virtual discussion format, with use of an online portal (also known as electronic portal, ePortal, electronic reading room) established by Constellation, if needed. The enclosed audit plan was discussed with your staff on August 1, 2022.

If you have any questions, please contact me at 301-415-3733 or at Robert.Kuntz@nrc.gov.

Sincerely,

/RA/

Robert Kuntz, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-373, 50-374, 50-254, and 50-265

Enclosure:

Audit Plan cc: Listserv

REGULATORY AUDIT PLAN TO SUPPORT REVIEW OF CRITICALITY SAFETY ANALYSIS THAT SUPPORT LICENSE AMENDMENT REQUESTS FOR DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, LASALLE COUNTY STATION, UNITS 1 AND 2, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-237, 50-249, 50 373, 50 374, 50-254, AND 50-265

1.0 BACKGROUND

By application dated June 8, 2022 (Agencywide Document Access and Management System (ADAMS) Accession No. ML22159A310) Constellation Energy Generation, LLC (Constellation) submitted an license amendment request (LAR) for Dresden Nuclear Power Station, Units 2 and 3 (Dresden) and by application dated June 30, 2021 (ML21183A169), as supplement by letters dated November 4, 2021 (ML21312A457) and June 17, 2022 (ML22172A175) and application dated October 25, 2021 (ML21298A168), as supplemented by letter dated November 3, 2021 (ML22194A086), Exelon Generation Company, LLC, submitted LARs for LaSalle County Station, Units 1 and 2 (LaSalle), and Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities) respectively. On February 1, 2022 (ML22032A333), Exelon Generation Company, LLC was renamed Constellation. The amendments request the use of new criticality safety analysis (CSA) methodology for performing criticality safety evaluations for fuel in the spent fuel pool.

The proposed changes to the CSA will use GESTAR II methodology for validating new fuel vault criticality safety. Due to the complex nature of this material, the U.S. Nuclear Regulatory Commission (NRC) staff has decided to conduct an audit for understanding under the Office of Nuclear Reactor Regulation Instruction LIC-111, Regulatory Audits.

2.0 REGULATORY AUDIT BASIS This is a request for an audit for understanding. Audits for understanding are a tool that the NRC staff has used to more effectively and efficiently understand the material which has been submitted for review. While they are an optional tool, they have been found to greatly reduce the number of requests for additional information and total number of hours necessary in performing the review and are generally seen by both the NRC staff and the licensee as a large efficiency gain.

3.0 REGULATORY AUDIT SCOPE The NRC will conduct a virtual audit for understanding of the Dresden, LaSalle, and Quad Cities LARs and supporting analysis.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff requests that Constellation make available the appropriate engineer(s) with expertise related to the LARs and who can address questions by the NRC staff. The engineer(s) will also make available to the NRC staff any references deemed appropriate.

5.0 TEAM AND REVIEW ASSIGNMENTS The regulatory audit will be held virtually. The audit team will consist of the following NRC staff:

Robert Kuntz, Lead Project Manager Surinder Arora, Project Manager Blake Purnell, Project Manager Kent Wood, Technical Reviewer 6.0 LOGISTICS The audit will be conducted from August 4, 2022, through September 2, 2022.

Constellation should provide the necessary documents and relevant licensee staff who can discuss the LARs and supporting analysis.

The audit will primarily be a discussion using a virtual platform (e.g., Microsoft Teams) for the purposes of gaining a clear understanding of the LARs and supporting analysis. This includes answering comprehension questions by the licensee.

If any additional information is submitted to the electronic reading room, the audit team will confirm with the licensee that the information made available on the online portal contains any sensitive or proprietary information. The audit team may request that representatives of Constellation answer audit team questions during the audit related to information provided on the portal at a mutually agreeable day and time by telephone or Microsoft Teams conference.

The NRC project managers will coordinate any changes to the audit schedule with the licensee.

7.0 SPECIAL REQUESTS The audit team would like access to documents if needed through an online portal (also known as eDocs, electronic reading room, ePortal) that allows the audit team to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the audit team has access to the online portal:

The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.

The online portal will be sufficiently secure to prevent the NRC staff from printing, saving, downloading, or collecting any information on the online portal.

Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.

User name and password information should be provided directly to the NRC staff. The NRC lead project manager will provide Constellation any additional names and contact information of the NRC staff if needed. All other communications should be coordinated through the NRC lead project manager.

8.0 DELIVERABLES An audit summary, which may be made public, will be provided within 90 days of the completion of the audit.

ML22214A004 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/SFNB/BC NAME RKuntz SRohrer SKrepel DATE 8/2/22 8/2/22 8/2/22 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME NSalgado RKuntz DATE 8/2/22 8/2/22