ML20353A344

Exemption Request for NRC Review Fees for the License Amendment Request for the Limerick Digital Modernization Project

ML20353A344
Person / Time
Site:	Limerick
Issue date:	12/18/2020
From:	Rafferty-Czincila S Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20353A344 (3)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 170.11(b)

December 18, 2020 ATTN: Document Control Desk Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Exemption Request for NRC Review Fees for the License Amendment Request for the Limerick Digital Modernization Project

Reference:

1. Exelon Letter-of-Intent to Submit a License Amendment Request for the Limerick Digital Modernization Project, dated December 11, 2020 (ADAMS Accession No. ML20346A026)

2. Limerick Generating Station - Digital Modernization Project LAR Pre-Submittal Meeting, dated June 12, 2020 (ADAMS Accession No. ML20160A053)

3. Summary of June 12, 2020 Public Teleconference with Exelon Generation Company, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2 (EPID L-2020-LRM-0016), dated June 30, 2020 (ADAMS Accession No. ML20175A240)

4. INL/LTD-20-58490 LWRS Vendor Independent Design Requirements for a Boiling Water Reactor Safety System Upgrade

5. Integrated Action Plan to Modernize Digital Instrumentation and Controls Regulatory Infrastructure (IAP Revision 2), dated January 31, 2018 (ADAMS Accession No. ML17277B643)

6. U.S. NRC Digital Instrumentation and Control Interim Staff Guidance-(ISG)-06, "Licensing Process," Revision 2 (ADAMS Accession No. ML18269A259)

In Reference 1, Exelon Generation Company, LLC (Exelon) transmitted a Letter-of-Intent (LOI) to the U.S. Nuclear Regulatory Commission (NRC) describing the planned submittal of a License Amendment Request (LAR) for the Limerick (LGS) Digital Modernization Project. The subject project implements a comprehensive and holistic digital modernization strategy across four protection systems (References 2 and 3). The application of advanced technologies further increases safety, reliability and efficiency. Modernization of protection systems at this scale is without precedent and this project will demonstrate for the domestic fleet the tangible

U.S. Nuclear Regulatory Commission Exemption Request for NRC Review Fees Docket Nos. 50-352 and 50-353 December 18, 2020 Page 2 benefits that can be realized by replacing original construction analog systems with advanced digital technologies.

The research that underlies this project is the product of a multi-year public / private partnership between the Department of Energy (DOE) and Exelon (Reference 4). From its inception, this project has been structured around key technical and regulatory advances that have come to fruition in recent years through collaboration between the industry and NRC to resolve long standing issues that have largely precluded modernization of protection systems (Reference 5).

The most relevant of these initiatives are:

1) Interim Staff Guidance 6 (ISG-6), Alternate Review Process (ARP) (Reference 6)

2) EPRI Digital Engineering Guide (EPRI 3002011816) and subordinate methodologies

3) Standardized Digital Design Process (NISP-EN-04)

This framework enables the insights, methods and strategies to be transportable across the industry. Exelon acknowledges that LGS is not the first plant to request use of the ARP.

Waterford Unit 3 requested initial use of the ARP as a lead plant. The Waterford project is a digital-to-digital replacement of a portion of one protection system. LGS will be the first licensee to request to use the ARP with a project scope which includes multiple protection system replacement. The LGS Digital Modernization Project is an analog-to-digital replacement of four protection systems which will provide a better demonstration of the success path to modernization. This will include use of draft Branch Technical Position (BTP) 7-19, Revision 8, when issued, to address software common cause failure.

Given the scale of the LGS Digital Modernization Project, the public facing research on which it is founded and the demonstration of the viability of multiple industry and regulatory initiatives, Exelon believes that this project has significant benefits for the industry, and by extension the public, in the form of long-term preservation of carbon-free generation. Exelon is therefore requesting an exemption from the NRC review fees associated with the evaluation of this LAR, in accordance with 10 CFR 170.11, "Exemptions."

With respect to the basis for the exemption request, Exelon requests that the NRC review fees associated with the NRC evaluation of the planned LAR and associated pre-submittal meetings be waived in accordance with 10 CFR 170.11(b), which states in part:

The Commission may, upon application by an interested person, or upon its own initiative, grant such exemptions from the requirements of this part as it determines are authorized by law and are otherwise in the public interest For the reasons discussed above, Exelon believes that this project satisfies the public interest attribute and therefore satisfies the standard for an NRC exemption of review fees described in 10 CFR 170.11(b). Exelon respectfully requests a decision on the exemption request for NRC review fees as soon as practicable to support timely and efficient scheduling of pre-submittal meetings and LAR development.

There are no regulatory commitments contained within this letter.

U.S. Nuclear Regulatory Commission Exemption Request for NRC Review Fees Docket Nos. 50-352 and 50-353 December 18, 2020 Page 3 If you have any questions concerning this submittal, please contact Frank Mascitelli at (610) 765-5512.

Sincerely, Rafferty-Czincila, Digitally signed by Rafferty-Czincila, Shannon Shannon DN: cn=Rafferty-Czincila, Shannon Date: 2020.12.18 14:05:50 -05'00' Shannon Rafferty-Czincila Director - Licensing Exelon Generation Company, LLC cc: USNRC Region I, Regional Administrator USNRC Project Manager, LGS USNRC Senior Resident Inspector, LGS USNRC Project Manager for the LGS Digital Modernization Project Wade DeHaas, Pennsylvania Bureau of Radiation Protection