ML25035A060

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Regulatory Audit in Support of License Amendment Request Related to Standby Gas Treatment System
ML25035A060
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 02/07/2025
From: Robert Kuntz
NRC/NRR/DORL/LPL3
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
Kuntz R, NRR/DORL/LPL3
References
EPID L-2024-LLA-0149
Download: ML25035A060 (1)


Text

February 7, 2025 David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - REGULATORY AUDIT IN SUPPORT OF LICENSE AMENDMENT REQUEST RELATED TO STANDBY GAS TREATMENT SYSTEM (EPID L-2024-LLA-0149)

Dear David Rhoades:

By letter dated November 4, 2024, Constellation Energy Generation, LLC (Constellation) submitted a license amendment request (LAR)for Quad Cities Nuclear Power Station, Units 1 and 2, Renewed Facility Operating License Nos. DPR-29 and DPR-30, respectively. The proposed LAR would extend the Completion Time for Technical Specifications (TS) 3.6.4.3, Standby Gas Treatment (SGT) System, Required Action D.1 on a one-time basis to support repair of the SGT common discharge exhaust line. Specifically, the proposed change extends the Required Action D.1 Completion Time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 14 days.

The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.

The NRC staff will conduct the audit virtually via Teams using a licensee-established electronic portal available to NRC staff from the date of this letter through March 14, 2025, with formal audit meetings to be scheduled during this period, as needed. The detailed audit plan is enclosed with this letter.

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

Sincerely,

/RA/

Robert Kuntz, Senior Project Manager Plant Licensing Branch LPL3 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265

Enclosure:

Audit Plan cc: Listserv

Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST TO EXTEND STANDBY GAS TREATMENT SYSTEM ALLOWED OUTAGE TIME CONSTELLATION ENERGY, LLC QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265

1.0 BACKGROUND

By letter dated November 4, 2024, Constellation Energy Generation, LLC (Constellation) submitted a license amendment request (LAR)for Quad Cities Nuclear Power Station, Units 1 and 2, Renewed Facility Operating License Nos. DPR-29 and DPR-30, respectively. The proposed LAR would extend the Completion Time for Technical Specifications (TS) 3.6.4.3, Standby Gas Treatment (SGT) System, Required Action D.1 on a one-time basis to support repair of the SGT common discharge exhaust line. Specifically, the proposed change extends the Required Action D.1 Completion Time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 14 days.

The staff from the U.S. Nuclear Regulatory Commissions(NRCs) Office of Nuclear Reactor Regulation(NRR) has initiated its review of the LARs in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19248C539).

2.0 REGULATORY AUDIT BASES A regulatory audit is a planned license, or regulation-related activity, that includes the examination and evaluation of the licensees non-docketed 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 LIC-111, Regulatory Audits (ML24309A281).

The NRC staff will perform the audit to support its evaluation of whether the licensees requests can be approved per Title 10 of the Code of Federal Regulations, section 50.90, Application for

amendment of license, construction permit, or early site permit. The audit will assist the NRC staff with understanding the LAR.

3.0 SCOPE The scope of the NRC staffs audit will focus on the following subjects:

Gain a better understanding of the temporary discharge line design and any risk perspective related to the temporary modification.

Gain a better understanding of initial conditions, inputs, and assumptions to the accident dose calculations (RADTRAD).

Gain a better understanding of the technical basis and supporting documentation which supports the use of the revised values for primary containment leak rate, secondary containment (reactor building) holdup/leak rate, and Engineered Safety Feature recirculation system leakage.

Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).

Discuss technical specification issues including proposed note wording, TS 3.6.4.3 Conditions A and B, and the bases for the proposed TS change.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff will request information and interviews throughout the audit period. The NRC staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff.

5.0 AUDIT TEAM The following table identifies the NRC audit team members, including contractors, and their respective focus areas:

Table 1: NRC Audit Team Composition Name Email Review Area (Organization)

Robert Kuntz Robert.Kuntz @nrc.gov Plant Licensing Branch III Derek Scully Derek.Scully@nrc.gov Containment and Plant Systems Branch David Coy David.Coy@nrc.gov Joshua Wilson Joshua.Wilson@nrc.gov Technical Specification Branch Thinh Dinh Thinh.Dinh@nrc.gov PRA Licensing Branch B Reinaldo Rodriguez Reinaldo.Rodriguez@nrc.gov Sean Meighan Sean.Meighan@nrc.gov Radiation Protection and Consequence Branch

6.0 LOGISTICS The audit will be conducted using a secure, online electronic portal, established by the licensee to present supporting documentation and calculations and by interviews with the licensees subject matter experts, virtually. The audit will begin from the date of this letter and last through March 14, 2025.

The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC project manager will coordinate with the licensee to set dates and times to discuss information needs and questions arising from the NRCs review of the audited items. The NRC staff may change and/or add audit dates and times when deemed necessary. Audit meeting agenda and questions will be sent in advance of the audit meeting.

7.0 SPECIAL REQUESTS The following conditions associated with the online web-based electronic portal should be maintained while the NRC staff and contractors on the audit team have access to the online portal:

The online electronic portal will be password-protected, and separate passwords will be assigned to each member of the audit team.

The online web-based electronic 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 electronic portal will be displayed on the login screen and will require acknowledgment by each user.

The licensee should provide username and password information directly to the NRC staff and contractors on the audit team, listed above. The NRC project manager will provide the licensee the names and contact information of the NRC staff and contractors who are added to the audit team. All other communications should be coordinated with the NRC project manager.

No data 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 develop any requests for additional information (RAIs), as needed, in accordance with LIC-115 and issue such RAIs separate from audit-related correspondence. The NRC staff will issue an audit summary report within approximately 90 days after the end of the audit and prior to completing its safety evaluations of the LARs.

ML25035A060 NRR-106 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/SCPB/BC NRR/DSS/STSB/BC NAME RKuntz SRohrer MValentin SMehta DATE 2/3/2025 2/4/2025 2/5/2025 2/4/2025 OFFICE NRR/DRA/ARCB/BC NRR/DRA/APLB/BC NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME KHsueh EDavidson IBerrios RKuntz DATE 2/6/2025 2/5/2025 2/7/2025 2/7/2025