ML23193B012
| ML23193B012 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/20/2023 |
| From: | Marshall M NRC/NRR/DORL/LPL1 |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| EPID L-2023-LLA-0025, EPID L-2023-LLE-0005 | |
| Download: ML23193B012 (1) | |
Text
July 20, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Rd.
Warrenville, IL 60555
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - AUDIT PLAN IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST AND EXEMPTION REQUEST FOR DIGITAL INSTRUMETNATION AND CONTROLS INSTALLATION SUPPORT (EPIDS L-2023-LLA-0025 AND L-2023-LLE-0005)
Dear Mr. Rhoades:
By letter dated February 17, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23052A023), Constellation Energy Generation, LLC (Constellation) submitted to the U.S. Nuclear Regulatory Commission (NRC) a license amendment request (LAR) to revise technical specifications and request an exemption from requirements of Sections 50.62(c)(3), (4) and (5) of Title 10 of the Code of Federal Regulation (10 CFR) to support a digital modernization project installation.
The U.S. NRC staff has reviewed Constellations LAR and determined that a regulatory audit would assist in the timely completion of the review. The NRC staff will conduct a regulatory audit to support its review 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 LAR and identify information that will require docketing to support the NRC staffs regulatory findings. The audit will be conducted from July 24, 2023, to August 31, 2023, through an online portal (also known as electronic portal, ePortal, or electronic reading room) established by Constellation. The enclosed audit plan was discussed with your staff on July 11, 2023.
If you have any questions, please contact me by telephone at 301-415-2871 or email to Michael.Marshall@nrc.gov, or Nick Smith by telephone at 301-415-2509 or email to Nicholas.smith@nrc.gov.
Sincerely,
/RA/
Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-352 and 50-353
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN TO SUPPORT REVIEW OF LICENSE AMENDMENT REQUEST FOR INSTALLATION SUPPORT OF DIGITAL INSTRUMENTATION AND CONTROLS UPGRADE TO PROTECTION SYSTEMS LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
1.0 BACKGROUND
By letter dated February 17, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23052A023), Constellation Energy Generation, LLC (Constellation) submitted to the U.S. Nuclear Regulatory Commission (NRC) a license amendment request (LAR) to revise technical specifications and request an exemption from requirements of Sections 50.62(c)(3), (4) and (5) of Title 10 of the Code of Federal Regulation (10 CFR) to support a digital modernization project installation.
The U.S. NRC staff has determined the need for a regulatory audit to be conducted in accordance with Office of Nuclear Reactor Regulation Office Instruction LIC-111, Regulatory Audits (ADAMS Accession No. ML082900195), for the NRC staff to examine the licensees non-docketed information with the intent to gain a better understanding of the LAR, to verify information, and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.
2.0 REGULATORY AUDIT BASIS The NRC staff (i.e., audit team) will perform the audit to support its evaluation of whether the licensees request meets the intent of Section 50.62(c)(3-5), BWR Requirements for reduction of risk from Anticipated Transient Without Scram (ATWS) events for light water cooled nuclear power plants, of Title 10 of the Code of Federal Regulation.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The audit team will review the licensees existing ATWS analysis of record to compare the baseline conditions with that proposed by the LAR and exemption request. The information in of the LAR as compared to the baseline ATWS analysis allows for an increased understanding of the changes to operational conditions and margin to the acceptance criteria.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff requests the licensee to have the following information readily available and accessible for the staffs review via an internet-based portal:
ATWS Analysis of Record, per Attachment 1, Section 3.5.1, this is The Thermal Power Optimization (TPO) ATWS analysis (0000-0097-1195)
Based on the review of the above documents, the NRC staff will determine whether it needs to request any additional documents to be made available on the portal or whether additional information needs to be submitted on the docket for the staff to complete the review of the requested changes.
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff:
Charley Peabody, Nuclear Engineer Nicholas Smith, Project Manager 6.0 LOGISTICS The audit will be conducted from July 24, 2023, to August 31, 2023, through an online portal (also known as electronic portal, ePortal, electronic reading room) established by Constellation.
The audit teams access to the online portal should be terminated on September 8, 2023.
If requested, the audit team will conduct a telephone conference with the licensee for the purposes of introducing the team, discussing the scope of the audit, and describing the information to be made available on the online portal. The audit team will also confirm with the licensee if 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 conference.
The NRC staff does not foresee the need for an onsite visit or in-person discussions between the NRC and licensee staff to discuss information to be provided on the portal at this time.
However, if the need for a such a meeting is identified in the future, the schedule for the audit will be adjusted accordingly. The NRC project manager will coordinate any changes to the audit schedule and location with the licensee.
7.0 SPECIAL REQUESTS The audit team would like access to the documents listed in Section 4.0 above 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 and contractors who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff and contractors 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.
Username and password information should be provided directly to the NRC staff and contractors. The NRC project manager will provide Constellation the names and contact information of the NRC staff who will be participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES An audit summary, which may be public, will be prepared within 60 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the NRC staff will issue requests for additional information to the licensee.
ML23193B012 NRR-106 OFFICE DORL/LLPB/PM DORL/LPL1/PM DORL/LPL1/LA DSS/SNSB/BC NAME NSmith MMarshall KZeleznock PSahd DATE 07/06/2023 07/11/2023 07/13/2023 07/20/2023 OFFICE DORL/LPL1/BC DORL/LPL1/PM NAME HGonzález MMarshall DATE 07/19/2023 07/20/2023