ML23289A244
| ML23289A244 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  (DPR-059) |
| Issue date: | 10/27/2023 |
| From: | Justin Poole Plant Licensing Branch 1 |
| To: | Rhoades D Constellation Energy Generation |
| Poole J | |
| References | |
| EPID L-2023-LLA-0096 | |
| Download: ML23289A244 (1) | |
Text
Enclosure October 27, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - AUDIT PLAN IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST REGARDING TECHNICAL SPECIFICATION SECTION 3.3.1.2 SOURCE RANGE MONITOR (SRM) INSTRUMENTATION (EPID L-2023-LLA-0096)
Dear Mr. Rhoades:
By letter dated June 28, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23179A021), Constellation Energy Generation, LLC (Constellation, the licensee), submitted a license amendment request (LAR) for James A. FitzPatrick Nuclear Power Plant, to the U.S. Nuclear Regulatory Commission (NRC). Specifically, the proposed LAR would modify the Technical Specification (TS) Section 3.3.1.2, Source Range Monitors (SRM) Instrumentation to allow for a lower required count rate for Surveillance Requirement (SR) 3.3.1.2.4 of 0.7 counts per second (cps) with a signal to noise ratio 20:1.
During the review of the LAR, the NRC staff identified items that require further clarification and detailed explanations. The NRC staff will conduct a regulatory audit to support its review of the LAR 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 LARs identifying information that will require docketing to support the NRC staffs regulatory findings.
The audit will be conducted using an online portal and teleconferences. The audit plan and supporting materials are enclosed.
If you have any questions, please contact me by telephone at 301-415-2048 or by e-mail to Justin.Poole@nrc.gov.
Sincerely,
/RA/
Justin Poole, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN REGARDING LICENSE AMENDMENT REQUEST TO MODIFY TECHNICAL SPECIFICATION SECTION 3.3.1.2 SOURCE RANGE MONITOR (SRM) INSTRUMENTATION JAMES A. FITZPATRICK NUCLEAR POWER PLANT CONSTELLATION ENERGY GENERATION, LLC.
DOCKET NO. 50-333
1.0 BACKGROUND
By letter dated June 28, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23179A021), the Constellation Energy Generation, LLC (Constellation, the licensee), submitted a license amendment request (LAR) to revise James A.
FitzPatrick Nuclear Power Plant (FitzPatrick) Technical Specifications (TSs). The requested changes would modify TS Section 3.3.1.2, Source Range Monitors (SRM) Instrumentation.
Specifically, the proposed change will allow for a lower required count rate for Surveillance Requirement (SR) 3.3.1.2.4 of 0.7 counts per second (cps) with a signal to noise ratio 20:1.
In this LAR, the licensee proposed to modify the SR 3.3.1.2.4 to incorporate an additional acceptance criterion that bases on a higher signal to noise ratio (minimum count rate of 0.7 cps is based on a signal to noise ratio of 20:1), as provided in General Electric Service Information Letter (GE SIL) 478 dated December 16, 1988 (Reference 1 of LAR). The JAF signal to noise ratio determination test, ST-5H (Reference 2 of LAR), is performed every 31days while in Mode 5 (refuel).
2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of information that provides the technical basis for the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, (ML19226A274) for the NRC staff to examine the licensees non-docketed information with the intent to gain a better understanding of the LARs, to verify information, and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.
Title 10 of the Code of Federal Regulations (10 CFR) 50.36, Technical Specifications, require that TS include SRs; where SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components are maintained that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The NRC staff seeks to understand how the change to the SRs are implemented.
3.0 SCOPE The purpose of this audit is to enable the NRC staff to come to a better understanding of the material submitted for review by allowing the NRC staff an opportunity to review documentation that is referenced in the LAR and to discuss the material with the licensee.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT Written responses to the attached audit discussion topics, and maintain continued availability of the following supporting documents (written as their file names) for the duration of the audit:
- 1. General Electric (GE) Service Information Letter (SIL) No. 478, SRM Minimum Count Rate Dated December 16, 1988 (Reference 1 of LAR)
- 2. James A. FitzPatrick Nuclear Power Plant Procedure: ST-5H SRM Signal to Noise Ratio Determination Test Revision 5 (Reference 2 of LAR).
The NRC staff requests the licensee to have the information above available and accessible for the NRC staffs review via a web portal within two weeks of the date of this audit plan. The NRC staff requests the licensee to notify the review team when an audit item is added to its portal by sending an e-mail to the NRC licensing project manager.
The staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. The NRC staff will not remove non-docketed information from the audit site or web portal.
5.0 AUDIT TEAM The following list identifies the NRC audit team members, and their respective focus areas:
Justin Poole, Licensing Project Manager, Justin.Poole@nrc.gov Hang Vu, Electronics Engineer, Hang.Vu@nrc.gov Richard Stattel, Acting Branch Chief, Instrumentation and Controls Branch, Richard.Stattel@nrc.gov 6.0 LOGISTICS The audit will be conducted remotely using video and teleconferencing and a secure, online portal, established by the licensee. The audit will begin within two weeks of the date of this audit plan and last through December 31, 2023. The NRC will establish an audit meeting(s) (e.g., a single, multi-day audit meeting; periodic audit meetings throughout the audit period) on mutually agreeable dates and times to discuss information needs and questions arising from the NRCs review of the audited items. The NRCs licensing project manager will inform the licensee of audit meeting dates when they are established, including the date of an audit kick-off meeting.
7.0 SPECIAL REQUESTS The following conditions associated with the online portal must be maintained throughout the duration so that the NRC staff and contractors on 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 on the audit team.
The online portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information from the web portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Constellation should provide username and password information directly to the NRC staff on the audit team, listed above. The NRC project manager will provide Constellation the names and contact information of any additional the NRC staff and contractors who are added to the audit team. All other communications should be coordinated with the NRC project manager. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal.
No information accessed by the audit team members will be retained by the NRC following the conclusion of the audit.
8.0 DELIVERABLES The NRC staff will issue an audit summary report within 90 days of the audit exit interview and prior to completing its safety evaluation of the LAR.
ML23289A244 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DEX/EICB/BC(A)
NAME JPoole KZeleznock RStattel DATE 10/16/2023 10/26/2023 10/04/2023 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME HGonzalez JPoole DATE 10/26/2023 10/27/2023