ML20175A240

Summary of June 12, 2020, Public Telephone Conference with Exelon Generation Company, LLC Regarding Planned Digital Modernization License Amendment Request

ML20175A240
Person / Time
Site:	Limerick
Issue date:	06/30/2020
From:	Marshall M Plant Licensing Branch 1
To:
Marshall M, NRR/DORL/LPL, 415-2871
References
EPID L-2020-LRM-0041
Download: ML20175A240 (5)

Text

June 30, 2020 LICENSEE:

Exelon Generation Company, LLC FACILITY:

Limerick Generating Station, Units 1 and 2

SUMMARY

OF JUNE 12, 2020, PUBLIC TELEPHONE CONFERENCE WITH EXELON GENERATION COMPANY, LLC REGARDING PLANNED DIGITAL MODERNIZATION LICENSE AMENDMENT REQUEST FOR LIMERICK GENERATING STATION, UNITS 1 AND 2 (EPID L-2020-LRM-0041)

On June 12, 2020, a telephone conference was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC (Exelon, the licensee). The purpose of the meeting was to discuss Exelons plan to submit a license amendment request (LAR) involving the modernization of instrumentation and control (I&C) systems at Limerick Generating Station (Limerick), Units 1 and 2. The meeting notice and agenda, dated May 28, 2020, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20162A088. The presentation slides used during the meeting are available in ADAMS at Accession Nos. ML20160A053 (Exelon) and ML20162A019 (NRC). A list of attendees is enclosed.

During the telephone conference, Exelon (1) discussed its plans to request a fee waiver (i.e.,

fee exemption request), (2) described the I&C modernization project scope, (3) described the current and proposed architecture of I&C systems, (4) discussed the use of the alternative review process described in NRC DI&C-ISG-06, Revision 2, Digital Instrumentation and Controls Licensing Process, Interim Staff Guidance, dated December 2018 (ADAMS Accession No. ML18269A259), and (5) provided a timetable for the planned LAR.

During Exelons discussion on its plans to submit a fee exemption request, the NRC staff noted that each decision concerning a fee exemption is made on a case-by-case basis, and the request needs to address the public interest. The NRC staff noted its interest in discussions on how separation would be accomplished on a common platform and the licensees vendor oversight plan at future pre-application meetings. Exelon plans to submit the LAR for three safety-related systems to the NRC in June 2021.

During the telephone conference, the NRC staff discussed lessons learned from other digital I&C amendment requests and pre-application interactions. The NRC staff stressed that:

Each of the key topics listed in DI&C-ISG-06, Revision 2, should be addressed in a pre-application meeting.

Early pre-application meetings are essential to ensure an efficient NRC staff review.

Changes to the schedule should be communicated to the NRC promptly to ensure the staff can align the necessary resources to complete the review.

The licensee should engage the NRC staff early concerning any complex digital designs, first-of-a-kind technical approaches, and deviations from referenced NRC-approved topical reports or guidance.

In response to a question from Exelon on whether the NRC staff planned to observe Exelons audits of its I&C vendor, the staff stated it would like to observe at least two audits conducted by Exelon.

No regulatory decisions were made during the meeting. Members of the public were in attendance. No comments or questions from the public were received during the meeting. No public meeting feedback forms were received.

Please direct any inquiries to me at 301-415-2871 or Michael.Marshall@nrc.gov.

/RA/

Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

List of Attendees cc: Listserv

Enclosure LIST OF ATTENDEES JUNE 12, 2020, MEETING WITH EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST INVOLVING DIGITAL MODERNIZATION Name Organization Andrea Veil U.S. Nuclear Regulatory Commission (NRC)

Bernard Dittman NRC Brian Green NRC DaBin Ki NRC Deanna Zhang NRC Eric Benner NRC Greg Galletti NRC Gregory Suber NRC Jeanne Johnston NRC Jigar Patel NRC Justin Vasquez NRC Kerri Kavanagh NRC Khadijah West NRC Michael Marshall NRC Michael Waters NRC Ramon Gascot NRC Richard Stattel NRC Robert Beaton NRC Rossnyev Alvarado NRC Samir Darbali NRC Steven Arndt NRC Tarico Sweat NRC Wendell Morton NRC Bob Dickenson Exelon Generation Company, LLC (Exelon)

Brink Sturmiollo Exelon Craig Myers Exelon Dave Helker Exelon Elliott Flick Exelon Farad Zaman Exelon Frank Mascitelli Exelon George Bonanni Exelon George Budock Exelon Jerry Segner Exelon John Connelly Exelon Mark Samselski Exelon Scott Schumacher Exelon Shannon Rafferty-Czincila Exelon

2 Name Organization Steven Hess Exelon Vikram Shah Exelon Pareez Golub Sargent & Lundy Bill Rosco Rolls Royce Brent Young Curtiss Wright Deann Releigh Curtiss Wright Diane Ralley Curtiss Wright Jeremy Davis Curtiss Wright Robert Ammon Curtiss Wright Theresa Sutter Curtiss Wright Brian Hanes Framatome Bryan Dorsey Framatome Lewis Wetzel Framatome Brian Johnson GE Hitachi Richard Miller GE Hitachi Skip Butler GE Hitachi David Harrell MPR Associates William Jessup MPR Associates David Multen None (Public)

Don Chase None (Public)

Ron Jarrett None (Public)

Yen Pun None (Public)

Gary Tuitt Westinghouse Tim Rozum Westinghouse Warren Odess Gillett Westinghouse Hong Han Deng Brampton IBMD Ira Poppell General Electric Steve Henika General Electric Jerry Mauck JLM Licensing Ken Scarola Nuclear Automation Engineering Kevin Deyette Nu Scale Power Paul Hunten Idaho National Laboratory Robert England Idaho National Laboratory Ted Quinn Technology Resources

ML20175A240 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME MMarshall LRonewicz JDanna MMarshall DATE 06/26/2020 06/27/2020 06/29/2020 06/30/2020