ML25325A351
| ML25325A351 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, Brunswick, Robinson, McGuire  |
| Issue date: | 12/09/2025 |
| From: | Shawn Williams NRC/NRR/DORL/LPL2-1 |
| To: | Gibby S Duke Energy, Nuclear Engineering |
| References | |
| EPID L-2025-LLA-0165 | |
| Download: ML25325A351 (0) | |
Text
December 9, 2025 Mr. Shawn Gibby Vice President Nuclear Engineering Duke Energy 525 S. Tryon St.
Charlotte, NC 28202
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, CATAWBA NUCLEAR STATION, UNITS 1 AND 2; MCGUIRE NUCLEAR STATION, UNITS 1 AND 2; AND H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - REGULATORY AUDIT IN SUPPORT OF REVIEW OF THE LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO USE ONLINE MONITORING METHODOLOGY (EPID L-2025-LLA-0165)
Dear Mr. Gibby:
By letter dated October 9, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25282A076), Duke Energy (the licensee) submitted a license amendment request (LAR) for Brunswick Steam Electric Plant, Units 1 and 2; Catawba Nuclear Station, Units 1 and 2; McGuire Nuclear Station, Units 1 and 2; and H.B. Robinson Steam Electric Plant, Unit 2. The proposed LAR would revise Technical Specification (TS) 1.1, Use and Application Definitions, and add new TS 5.5.16 (Brunswick), TS 5.5.18 (Catawba),
TS 5.5.19 (McGuire), and TS 5.5.19 (H.B. Robinson), entitled, Online Monitoring Program.
Duke Energy proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed LAR is based on the U.S. Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Corporation (AMS) topical report, AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (ADAMS Accession No. ML21235A493).
The NRC staff has identified the need for a regulatory audit to examine Duke Energys 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 approximately January through March, 2026, with formal audit meetings to be scheduled during this period as needed. The NRC staff reserves the right to extend the audit, if necessary. The detailed audit plan is enclosed with this letter.
If you have any questions, please contact me at (301) 415-1009 or by e-mail at Shawn.Williams@nrc.gov.
Sincerely,
/RA/
Shawn A. Williams, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-325, 50-324 50-413, 50-414, 50-369, 50-370, 50-261
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST USE OF ONLINE MONITORING METHODOLOGY DUKE ENERGY CAROLINAS, LLC AND DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NOS. 50-325, 50-324, 50-413, 50-414, 50-369, 50-370, AND 50-261
1.0 BACKGROUND
By letter dated October 9, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25282A076), Duke Energy submitted a license amendment request (LAR) for the Brunswick, Catawba, McGuire, and Robinson nuclear units. The proposed LAR would revise Technical Specification (TS) 1.1, Use and Application Definitions, and add new sections to the administrative controls portion of the TSs to implement an Online Monitoring (OLM) Program based on the NRC-approved Analysis and Measurement Services Corporation (AMS) topical report, AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters.
Duke Energy proposes to use OLM methodology to transition from time-based surveillance intervals for channel calibrations to a condition-based calibration frequency determined by OLM results. The NRC staff from the Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures (ML19248C539).
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, verify information, and identify information that will require docketing to support the basis of a licensing or regulatory decision. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1 (ADAMS Accession No. ML19226A274).
The NRC staff will perform the audit to support its evaluation of whether Duke Energys LAR can be approved per Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit. The audit will assist the NRC staff with understanding the licensees proposed OLM LAR.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The objectives of the audit are as follows:
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the NRC staffs evaluation of the technical basis used for this application.
Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify questions and requests that may become formal requests for additional information (RAI) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).
The NRC staff will audit the technical information and methods that the licensee used to determine the impact on the plant and the licensees evaluation of defense-in-depth.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff will request information and audit meetings throughout the audit period. The NRC staff will use an audit items list to identify the information (e.g., methodology, process information, and calculations) to be audited. The NRC staff will provide the final audit items list as an enclosure to the audit summary report, which will be publicly available.
Throughout the audit period, the NRC staff will provide Duke Energy with audit questions and audit-related requests so that the licensee can better prepare for audit discussions. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff. The NRC staff requests the licensee to have the requested audit information listed in the enclosure to be readily available and accessible for the NRC staffs review via a web-based portal.
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR:
Shawn Williams, NRR/DORL, Senior Project Manager Gilberto Blas Rodriguez, NRR/DEX/EICB (Instrumentation & Controls Branch)
Fredrick O'Brien, NRR/DEX/EICB (Instrumentation & Controls Branch)
Tarico Sweat, NRR/DSS/STSB (Technical Specifications Branch) 6.0 LOGISTICS To support the review schedule, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and a web-based portal or other virtual meeting space created by the licensee. The NRC staff information requests and communications with licensee staff will be coordinated through the NRCs licensing project manager.
A desktop audit is planned for January through March, 2026. The NRC licensing project manager will coordinate with the licensees point of contact to set dates and times to discuss any information needs or questions that arise during the review.
The NRC staff requests the licensee to have the information referenced in Section 4.0 of this audit plan available and accessible for the NRC staffs review via an internet-based portal when the desktop audit begins. Any supplemental information requested by the NRC staff should be made available and accessible within five days of the NRCs notification to the licensee of the new requests. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer need access to the portal. The NRC staff requests that the licensee notify the NRCs licensing project manager when an audit item is added to the portal by sending an email to the NRC licensing project manager.
7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a web-based portal that allows the NRC staff and contractors to access documents over the internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password and/or other web-based portal access information should be provided directly to members of the NRC staff and contractors as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES The NRC staff will develop any RAI, as needed, via NRR Office Instruction LIC-115 and issue such RAI separately from audit-related correspondence. The NRC staff will issue an audit summary report prior to completing its review of the LAR.
Enclosure Initial Audit Items List Item #
Audit Item 1
AMS Report BRU2501R0, OLM Amenable Transmitters Report for Brunswick Units 1 and 2 2
AMS Report CAT2501R0, "OLM Amenable Transmitters Report for Catawba Units 1 and 2 3
AMS Report MCG2405R0, "OLM Amenable Transmitters Report for McGuire Units 1 and 2 4
AMS Report HBR2501R0, "OLM Amenable Transmitters Report for H.B. Robinson Unit 2 5
AMS Report BRU2502R0, OLM Analysis Methods and Limits Report for Brunswick Units 1 and 2 6
AMS Report CAT2502R0, OLM Analysis Methods and Limits Report for Catawba Units 1 and 2 7
AMS Report MCG2406R0, OLM Analysis Methods and Limits Report for McGuire Units 1 and 2 8
AMS Report HBR2504R0, OLM Analysis Methods and Limits Report for H.B.
Robinson Unit 2 9
AMS Report BRU2503R0, OLM Drift Monitoring Program Report for Brunswick Units 1 and 2 10 AMS Report CAT2503R0, OLM Drift Monitoring Program Report for Catawba Units 1 and 2 11 AMS Report MCG2407R0, OLM Drift Monitoring Program Report for McGuire Units 1 and 2 12 AMS Report HBR2503R0, OLM Drift Monitoring Program Report for H.B. Robinson Unit 2 13 AMS Report BRU2504R0, OLM Noise Analysis Program Report for Brunswick Units 1 and 2 14 AMS Report CAT2504R0, OLM Noise Analysis Program Report for Catawba Units 1 and 2 15 AMS Report MCG2408R0, OLM Noise Analysis Program Report for McGuire Units 1 and 2 16 AMS Report HBR2504R0, OLM Noise Analysis Program Report for H.B. Robinson Unit 2
ML25325A351 NRR-106 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DEX/EICB/ABC NAME SWilliams KZeleznock NCarte DATE 12/4/2025 12/4/2025 12/5/2025 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley SWilliams DATE 12/9/2025 12/9/2025