ML24299A255
| ML24299A255 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 11/25/2024 |
| From: | Joel Wiebe Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Wiebe J | |
| Shared Package | |
| ML24299A259 | List: |
| References | |
| EPID L-2024-LLA-0072 | |
| Download: ML24299A255 (1) | |
Text
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION November 25, 2024 David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS. 1 AND 2 - AUDIT PLAN IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST TO TRANSITION TO FRAMATOME GAIA FUEL (EPID L-2024-LLA-0072)
Dear David P. Rhoades:
By letter dated May 28, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24149A126), Constellation Energy Generation, LLC (Constellation, the licensee), submitted a license amendment request (LAR) for Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2, to the U.S. Nuclear Regulatory Commission (NRC).
Specifically, the proposed LAR would make several technical specification changes to allow transition to Framatome GAIA fuel.
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 LAR and may identify 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.
to this letter contains proprietary information. When separated from, this document is DECONTROLLED.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION If you have any questions, please contact me by telephone at 301-415-6606 or via email at Joel.Wiebe@nrc.gov.
Sincerely,
/RA/
Joel S. Wiebe, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, STN 50-456, and STN 50-457
Enclosures:
- 1. Proprietary Audit Plan
- 2. Non-proprietary Audit Plan cc: Listserv
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION ENCLOSURE 2 REGULATORY AUDIT PLAN REGARDING LICENSE AMENDMENT REQUEST TO TRANSITION TO FRAMATOME GAIA FUEL BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS. 1 AND 2 CONSTELLATION ENERGY GENERATION, LLC.
DOCKET NOS. STN 50-454, STN 50-455, STN 50-456, AND STN 50-457 (NON-PROPRIETARY)
Proprietary information pursuant to Section 2.390 of Title 10 of the Code of Federal Regulations has been redacted from this document.
Redacted Proprietary information is identified by empty double brackets.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION REGULATORY AUDIT PLAN REGARDING LICENSE AMENDMENT REQUEST TO TRANSITION TO FRAMATOME GAIA FUEL BRAIDWOOD STATION, UNITS 1 AND 2, AND BYRON STATION, UNIT NOS. 1 AND 2 CONSTELLATION ENERGY GENERATION, LLC.
DOCKET NOS. STN 50-454, STN 50-455, STN 50-456, AND STN 50-457
1.0 BACKGROUND
By application dated May 28, 2024 (Agencywide Documents Access and Management System(ADAMS) Accession No.ML24149A125), Constellation Energy Generation, LLC (CEG; the licensee) submitted a license amendment request (LAR) for Braidwood Station, Units 1 and 2 (Braidwood), and Byron Station, Units 1 and 2 (Byron). The proposed amendments would revise technical specifications to allow the use of Framatome GAIA fuel at Braidwood and Byron.
The U.S. Nuclear Regulatory commission (NRC) staff has reviewed the licensees submittal and determined that a regulatory audit of the information identified in the Information Request section below would assist in the timely completion of the subject LAR review process. The NRC staff is continuing to review other aspects of the licensees submittal and may identify the need for additional audit subjects by separate correspondence.
2.0.
REGULATORY AUDIT BASES An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this LAR review because the NRC staff will have an opportunity to minimize the potential for requests for additional information and ensure no unnecessary burden will be imposed by requiring the licensee to address issues that are no longer necessary to make a safety determination. The NRC staff is requesting an initial set of internal licensee information to be audited by the staff using an online reference portal. Upon completion of this audit, the NRC staff is expected to achieve the following.
- 1.
Confirm internal licensee information that supports statements made in the LAR.
- 2.
Determine whether the information included in the documents is necessary to be submitted to support a safety conclusion.
The audit information the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION 3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The purpose of the remote audit is to gain a more detailed understanding of the information supporting the licensees request to transition to Framatome GAIA fuel at Braidwood and Byron.
The areas of focus for the regulatory audit are the information contained in the licensees submittal and all associated and relevant supporting documentation (e.g., methodology, process information, calculations, etc.) identified below. The audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ML19226A274).
4.0 INFORMATION REQUESTS Please make the following information for the NRC staff to audit via an online reference portal:
- 2. Calculations performed for both the small break loss of coolant accident (SBLOCA) and the realistic large break loss of coolant accident (RLBLOCA) evaluations.
- 3. Calculations performed for post-LOCA long term cooling that demonstrate compliance with Title 10 of the Code of Federal Regulations (10CFR) section50.46(b)(5).
- 4. Technical Specifications Bases change pages, when available.
- 5. Calculations performed to determine the results presented in Table 2-1 and Table 2-2 of 7 of the LAR.
- 6. Calculations to determine mixed core penalties for both Framatome and Westinghouse fuel.
- 7. Calculations to determine the impact of the penalty associated with the lower plenum flow anomaly.
- 8. WCAP-16676, Analysis Update for the Inadvertent Loading Event.
- 9. Calculations or evaluations performed supporting the treatment of parameter GCN-7a as discussed in Attachment 17 of the LAR under the method of adherence to Limitation and Condition 25.
- 10. Plant-specific calculations performed using the ARITA methodology to support the LAR.
- 11. Calculations supporting the determinations of ((
)), in accordance with Limitation and Condition 3 of ANP-10339 and as discussed in Attachment 17 of the LAR.
- 12. ((
)) discussed in Attachment 17 of the LAR under the method of adherence to Limitation and Condition 5 of ANP-10339.
- 13. ((
)) obtained under existing plant programs and procedures that are relevant to the ARITA methodology that would constitute the basis for comparison with proposed ((
)) in accordance with Limitation and Condition 27.
- 14. Attachment6 of the LAR states that Framatome performed testing in accordance with WCAP-17788, Volume6. Attachment 6 also states that the testing resulted in GAIA fuel-specific limitations that have been incorporated in WCAP-17788, Revision1, and this testing program and results are available for audit. Provide the testing program and results for review.
- 15. In our review of the Byron/Braidwood LAR and the associated RADTRAD runs, we are coming up with dose results in the three receptor locations which are somewhat higher
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION than presented in the LAR. At this point, the only results of concern are the control room dose results. This could be resulting from the import of the earlier version (3.03) of RADTRAD to the current version (5.03). However, we have not run into this large of a discrepancy in previous imports. We would like to discuss these results with Constellation and would like Constellation to have the ability to share its TEAMS screen showing its RADTRAD runs.
- 16. ANP-10339 Limitation and Condition 1 Method of Adherence on Page 2-2 of ANP-4087 refers only to Chapter 15 of the Standard Review Plan. Describe any other chapter deviations if any that could affect plant-specific accident sequences or state that there are none (for instance parts of LOCA analysis in Chapter 6, or Fire Initiators in Chapter 9).
- 17. ANP-10339 Limitation and Condition (L&C) 12 Method of Adherence on Page 2-11 of ANP-4087. Provide the analysis for audit.
- 18. ANP-10339 Limitation and Condition 25 Method of Adherence on Page 2-24 of ANP-4087. Provide the analysis for audit.
- 19. XN-75-32 Limitation and Condition 4 Method of Adherence on Page 2-56 of ANP-4087.
Clarify that Constellation is using Framatomes methodology and is not using the non-conservative procedure reverenced in this L&C and further explain how Constellation considers Framatomes conservative and compliant 5.0 AUDIT TEAM Key licensee personnel involved in the development of the LAR should be made available for interactions on a mutually agreeable schedule to respond to any questions from the NRC staff.
Team Member Division Area of Responsibility Email Joel Wiebe NRR/DORL/LPL3 Project Management Joel.Wiebe@nrc.gov Jo Ambrosini NRR/DSS/SNSB Technical Review Josephine.Ambrosini@nrc.gov Robert Beaton NRR/DSS/SNSB Technical Review Robert.Beaton@nrc.gov Richard Fu NRR/DSS/SFNB Technical Review Richard.Fu@nrc.gov Logan Gaul NRR/DSS/SNSB Technical Review Logan.Gaul@nrc.gov Ravi Grover NRR/DSS/STSB Technical Review Ravinder.Grover@nrc.gov Kevin Heller NRR/DSS/SFNB Technical Review Kevin.Heller@nrc.gov John Lehning NRR/DSS/SFNB Technical Review John.Lehning@nrc.gov Charley Peabody NRR/DSS/SNSB Technical Review Charley.Peabody@nrc.gov Jack Vande Polder NRR/DSS/SFNB Technical Review Jack.Vandepolder@nrc.gov Sean Meighan NRR/DRA/ARCB Technical Review Sean.Meighan@nrc.gov 6.0 LOGISTICS The audit will be conducted remotely from October 31,2024, through January31, 2025, through an online portal established by the licensee. The NRC staff and contractors access to the online portal should be terminated following closure of the audit.
The NRC staff requests to conduct remote meetings with CEG staff to discuss audit questions at mutually agreeable times to be determined after the start of the audit.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION 7.0 SPECIAL REQUESTS The NRC staff would like access to the documents listed above in section 4.0 through an online portal that allows the NRC staff and contractors to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff and contractors have 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 CEG the names and contact information of the NRC staff and contractors who will be participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES The NRC team will develop an audit summary report to convey the results. The report will be placed in ADAMS within 90 days of the completion of the final audit session. The audit information the NRC staff determines to be necessary to support the development of the NRCstaffs safety evaluation will be requested to be submitted on the docket.
ML24299A259 (Package)
ML24299A251 (Proprietary)
ML24299A255 (Non-Proprietary)
OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/SNFB/BC NAME JWiebe SRohrer SKrepel DATE 10/24/2024 10/28/2024 11/1/2024 OFFICE NRR/DSS/SCPB/BC NRR/DSS/STSB/BC NRR/DRA/ARCB NAME HWagage for, MValentin SMehta KHsueh DATE 11/1/2024 11/20/2024 11/21/2024 OFFICE NRR/DSS/SNSB NRR/DORL/LPL3/BC(A)
NRR/DORL/LPL3/PM NAME RBeaton (A)
RKuntz JWiebe DATE 11/6/2024 11/22/2024 11/25/2024