ML25227A151
| ML25227A151 | |
| Person / Time | |
|---|---|
| Site: | Crane  (DPR-033) |
| Issue date: | 09/05/2025 |
| From: | Ballard B Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Wall, SP | |
| References | |
| EPID L-2025-LLA-0102, TS 5.4.1 | |
| Download: ML25227A151 (1) | |
Text
September 5, 2025 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:
CHRISTOPHER M. CRANE CLEAN ENERGY CENTER - AUDIT PLAN IN SUPPORT OF REVIEW LICENSE AMENDMENT REQUEST TO REVISE LICENSE CONDITION 2.b.(2) AND RESTORE TECHNICAL SPECIFICATION 5.4.1 TO ALLOW RECEIPT OF NEW REACTOR FUEL (EPID L-2025-LLA-0102)
Dear Mr. Rhoades:
By letter dated June 27, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25178A294), Constellation Energy Generation, LLC (CEG),
requested an amendment to Renewed Facility License No. DPR-50 for the Crane Clean Energy Center (CCEC). The proposed amendment would revise license condition 2.b.(2) to allow receipt and possession of new reactor fuel and new sealed neutron sources for reactor startup, and reinstate technical specification 5.4.1, New Fuel Storage, which establishes the conditions of the spent fuel pools and new fuel storage vault necessary for compliance with Title 10 of the Code of Federal Regulations (10 CFR) 50.68, Criticality accident requirements.
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 audit will be conducted using an online portal and teleconferences. Formal audit meetings using video and teleconferencing will be scheduled as needed. The audit plan and supporting materials are enclosed.
D. Rhoades If you have any questions, please contact me at 301-415-0680 or via e-mail at Brent.Ballard@nrc.gov.
Sincerely, Brent T. Ballard, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289
Enclosure:
Audit Plan cc: Listserv BRENT BALLARD Digitally signed by BRENT BALLARD Date: 2025.09.05 09:09:10 -04'00'
Enclosure REGULATORY AUDIT PLAN REGARDING LICENSE AMENDMENT REQUEST TO ALLOW RECEIPT OF NEW REACTOR FUEL CONSTELLATION ENERGY GENERATION, LLC CHRISTOPHER M. CRANE CLEAN ENERGY CENTER DOCKET NO. 50-289
1.0 BACKGROUND
On September 20, 2024, Constellation Energy Generation, LLC (CEG, the licensee) announced their intent to restore commercial power operation at the Christopher M. Crane Clean Energy Center (CCEC). On November 4, 2024, CEG submitted a letter, Regulatory Path to Reauthorize Power Operations (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24310A104), describing the approach CEG intends to use to restore the operating reactor license basis (ORLB), which is necessary to commence power operations. Prior to transitioning to the ORLB, CEG would like to receive, possess, and store new reactor fuel and new sealed neutron sources for reactor startup at the CCEC.
By letter dated June 27, 2025 (ML25178A294), CEG submitted a license amendment request (LAR) to Renewed Facility License No. DPR-50 for the CCEC. The proposed amendment would revise license condition 2.b.(2) to allow receipt and possession of new reactor fuel and new sealed neutron sources for reactor startup, and reinstate technical specification (TS) 5.4.1, New Fuel Storage, which establishes the conditions of the spent fuel pools (SFP) and new fuel storage vault (NFV) necessary for compliance with Title 10 of the Code of Federal Regulations (10 CFR) 50.68, Criticality accident requirements.
The U.S. Nuclear Regulatory Commission (NRC) staff has initiated its review of the LAR in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction (OI) LIC-101, License Amendment Review Procedures (ML19248C539) and has determined that a regulatory audit of the information identified in the Information Requests section below would assist in the timely completion of the review process. The audit will be conducted in accordance with NRR OI LIC-111, Revision 2, Regulatory Audits (ML24309A281). The NRC staff continues 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 A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review and gaining insights into the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.
In accordance with 10 CFR 50.36, TS, nuclear power reactor facilities in decommissioning that have submitted certifications required by paragraph (a)(1) of 10 CFR 50.82, Termination of license, such as the CCEC, will develop TS involving safety limits, limiting safety system settings, and limiting control system settings; limiting conditions for operation; surveillance requirements; design features; and administrative controls on a case-by-case basis. The TSs will be derived from the analyses and evaluation included in the safety analysis report.
In accordance with 10 CFR 50.68, licensees shall comply with 10 CFR 70.24, Criticality accident requirements, or, in lieu of maintaining a monitoring system capable of detecting criticality as described in 10 CFR 70.24, the provisions listed in 10 CFR 50.68(b) regarding plant procedures for handling and storage of fuel, requirements on the estimated ratio of neutron production to neutron absorption and leakage (k-effective) for fuel storage, quantity of special nuclear material stored onsite, radiation monitoring in storage and handling areas, fuel enrichment of fresh fuel assemblies, and documentation of compliance with 10 CFR 50.68 in the updated final safety analysis report (UFSAR).
In accordance with 10 CFR 73.67(c)(1), licensees who possess, use, transport, or deliver to a carrier 10kg or more of special nuclear material of low strategic significance shall submit a security plan or an amended security plan describing how the licensee will comply with the appropriate requirements of 10 CFR 73.67, including schedules of implementation.
3.0 SCOPE Along with appropriate discussion, the audit team will view any documentation and calculations that provide technical support for the LAR to:
Establish an understanding of areas where the NRC staff has identified potential concerns with the LAR to enable the staff to issue clear requests for information and for the licensee to provide quality and timely responses.
Identify questions and requests that may become formal requests for additional information (RAI) per NRR Office Instruction LIC-115, (Revision 1) Processing Requests for Additional Information (ML21141A238).
Gain a better understanding of the bases underlying the LAR and confirm the NRC staffs understanding of the LAR.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff requests CEG to make available the appropriate licensee staff with intimate knowledge of the following areas, and who can address comprehensive questions by the NRC staff:
CCECs compliance with the criteria of 10 CFR 50.68(b).
The proposed revisions to the TS by the LAR to support receipt, possession, and storage of new reactor fuel and new sealed neutron sources. The NRC staff would like to discuss considerations by CEG on TS-related items that are not discussed in the LAR, including, but may not be limited to:
o Restoration of the surveillance requirement (SR) for the SFP boron concentration, and any associated TS that should be restored because of restoring a SR.
o Restoration of certain TS administrative requirements for fuel handlers, procedures for safe storage of nuclear fuel, radiological monitoring, and fuel handling, NRC reporting and records retention, and records of new and irradiated fuel.
o Restoration of the post-defueled TS to those that were in place the last time fuel was in the SFP at the CCEC. (Definitions and General Action Requirements and Surveillance Requirement Applicability.)
Restoration of systems and programs that are necessary for restoration of the NFV and SFP, including, but may not be limited to:
o Material condition of the neutron absorbing materials (NAM) in the SFP.
o Restoration of the NAM monitoring program identified in CCECs (Three Mile Island Nuclear Station, Unit 1, at time of submittal) response to Generic Letter (GL) 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools (ML16308A470, as supplemented by letter dated January 25, 2018 (ML18025A799).
o Ensuring that all support systems, structures, and components associated with the NFV and SFP are operational.
Following discussions, the NRC staff may provide questions and request responses from CEG on the portal for review, which may become formal requests for additional information.
The NRC staff requests that the following documents and any supporting documents be made available to the staff in CEGs electronic reading room:
Any materials CEG determines to be supportive of the discussion topics above.
Three Mile Island Part 37 Security Plan for the Protection of Category 1 and Category 2 Quantities of Radioactive Material and Part 73.67 Security Plan for the Protection of Special Nuclear Material of Moderate and Low Significance (Material Security Plan).
The NRC staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. If the information requested is unable to be placed on a portal (i.e., security-related information), the NRC project manager will coordinate with CEG for review. The NRC staff will not remove non-docketed information from the audit site or web portal.
5.0 AUDIT TEAM The audit will be conducted by NRC staff from the NRR Division of Safety Systems (DSS),
Nuclear Methods and Fuel Analysis Branch (SFNB), and the Technical Specification Branch (STSB), as well as staff from the Office of Nuclear Security and Incident Response (NSIR),
Division of Physical and Cybersecurity Policy (DPCP), Reactor Physical Protection Branch (RPPB). The audit will be led by staff from the NRR Division of Operating Reactor Licensing (DORL). NRC staff from other organizations may be assigned to the team as appropriate and others may participate as observers.
Brent Ballard, Project Manager, NRR/DORL/Plant Licensing Branch III (LPL3)
Brent.Ballard@nrc.gov Justin Poole, Project Manager, NRR/DORL/LPL3 Justin.Poole@nrc.gov Kent Wood, Senior Nuclear Engineer, NRR/DSS/SFNB Kent.Wood@nrc.gov Steve Smith, Senior Safety and Plant Systems Engineer, NRR/DSS/STSB Stephen.Smith@nrc.gov Steve Sarver, Security Specialist, NSIR/DPCP/RPPB Steven.Sarver@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 on September 22, 2025. The NRC staff requests the portal remain open and accessible until final RAIs are issued. The NRC will establish an audit meeting(s) 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 kickoff meeting.
7.0 DELIVERABLES The NRC staff will issue an audit summary report within 90 days of the audit exit.
- e-Concurrence OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NAME BBallard SLent IBerrios DATE 8/18/2025 8/18/2025 8/19/2025 OFFICE NRR/DORL/LPL3/PM NAME BBallard DATE 9/5/2025