ML22249A097

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Constellations Open Presentation for September 8, 2022 Partially Closed Public Meeting
ML22249A097
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 09/08/2022
From:
Constellation Energy Generation
To: Marshall M
NRC/NRR/DORL/LPL1
M Marshall, NRR/DORL/LPL1 301-415-2871
References
Download: ML22249A097 (27)
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Limerick Generating Station Digital Modernization Project LAR Pre-submittal Meeting NRC Pre-submittal Meeting September 8, 2022

oLicensing Darani Reddick, Licensing Director Frank Mascitelli, Licensing Lead Laura Lynch, LGS Regulatory Assurance Manager Jim Berg, LGS Regulatory Assurance Pareez Golub, Digital Licensing SME oEngineering Mark DiRado, Central Design Organization (CDO) Director John Connelly, Central Design Organization Manager Mark Samselski, CDO - Lead Responsible Engineer George Bonanni, CDO - Senior Staff Engineer Mike Foote, CDO - Senior Staff Engineer Scott Schumacher, Systems Engineering Introductions - Constellation Project Team 1

oProject Management Steve Hesse, Project Director Dave Molteni, Senior Manager and Station Lead Jerry Segner, Principal Project Manager Kayla Marriner, Project Manager oOperations Paul Krueger, Senior Operations Specialist oNuclear Oversight Dave Peiffer, Performance and Assessment Lead Introductions - Constellation Project Team 2

oProject Management

  • Mark Lloyd, Sr. Director of Project Execution and Delivery
  • Dominic Mocello, Project Manager
  • Boyan Setchenski, Program Manager oEngineering
  • Ken Lunz, Director of Safety System Engineering
  • Suresh Channarasappa, Consulting Engineer for Equipment Qualification
  • Warren Odess-Gillett, Lead - Licensing
  • Steve Merkiel, Functional & System Design Lead Introductions - Westinghouse Project Team 3

oOpen / Public Session

  • Introductions
  • Project Update/Schedule
  • License Amendment Request (LAR) Preview (ISG-06 Enclosure B)
  • VOP / VOP Summary
  • HFE follow-up from June 2022 meeting
  • Elimination of Turbine Enclosure - Main Steam Line Tunnel Temperature - High Isolation Function
  • Implementation LAR Overview oClosed Session
  • SyRS / SyDS LAR content
  • Equipment Qualification Summary Report (EQSR)
  • Deterministic behavior
  • PPS and DCS Power Supply Agenda / Opening Remarks 4

5 Project Update/Schedule

Submit LAR 09/30/22 NRC Acceptance Letter Issued 12/02/22 Conceptual Verification (CV) - Complete 12/09/22 Preliminary Validation (PV) - Complete 02/17/23 Submit LAR Supplements CV Report 02/09/23 SyDS Rev 2 02/17/23 PV RSR 03/30/23 Seismic EQ 04/18/23 Environmental EQ 05/03/23 EMC EQ 06/16/23 Integrated System Validation - Complete 08/31/23 Integrated FAT - Complete 12/22/23 LAR SER Issued 03/06/24 LGS Unit 1 Outage Install - Start 04/08/24 6

Project Schedule

7 LAR Preview

  • Cover letter
  • Evaluation of Proposed Change (Attachment 1)

System description, current requirements, reason for, and description of the proposed changes Required information per DI&C-ISG-06 Enclosure B, Alternate Review Process Description of Licensing Technical Report (LTR) (previously submitted)

RRCS Reclassification (addressed in LTR)

Elimination of RRCS Feedwater Runback function (addressed in LTR)

Elimination of Turbine Enclosure - High Temp. MSL Isolation function D3 CCF Coping Analysis (previously submitted)

Factory Acceptance Test / Site Acceptance Test Surveillance Requirement (SR) Elimination (addressed in LTR)

  • Technical Specification (TS) Changes (Attachment 2)

TS markups and clean pages TS Bases markups (information only)

Description of Changes Format is similar to ITS Conversion 8

LAR Preview

  • Attachments System Requirements Specification (SyRS), Revision 1 Failure Modes and Effects Analysis (FMEA)

System Design Specification (SyDS), Revision 1 Equipment Qualification Summary Report (EQSR)

Human Factors Engineering VOP Summary Draft UFSAR Markups (for information only)

Regulatory Commitment 9

LAR Preview

10 LAR Preview: DI&C ISG-06, Revision 2, Enclosure B 1.1 Summary of Application Software Planning and Processes (see D.4)

Addressed in WCAP-18598-P, "Licensing Technical Report for the Limerick Generating Station Units 1 & 2 Digital Modernization Project," Revision 0 (LTR), Section 5, "PPS - I&C System Development Processes (D.4)." Document previously submitted on August 12, 2022 (ADAMS Accession No. ML22224A146) 1.2 Summary of Vendor Oversight Plan (see C.2.2)

LAR, Attachment 11 1.3 Approved Topical Report Safety Evaluation (see D.5)

Addressed in LAR, Attachment 1, "Evaluation of Proposed Change," Section 3.1, "DI&C-ISG-06 Alternate Review Process (ARP) LAR Contents" and LTR, Section 6, "PPS - Applying a Referenced Topical Report Safety Evaluation (D.5)"

WCAP-16097-P, "Common Qualified Platform Topical Report," Revision 5 (ADAMS Accession No. ML21140A104)

WCAP-16096-P, "Software Program Manual for Common Q'Systems," Revision 5.1, (ADAMS Accession No. ML21146A203) 1.4 System Description (see D.1)

Addressed in LAR, Attachment 1, Section 2.1, "System Description and Operation," and LTR, Section 2, "Plant System Description (D.1) 1.5 System Architecture (see D.2)

Addressed in LTR, Section 3, "System Architecture (D.2)

System Requirements Specification (SyRS), Revision 1 System Design Specification (SyDS), Revision 1 System Design Specification (SyDS), Revision 2 (submitted later) 1.6 Summary of Hardware Equipment Qualification (see D.3)

LAR, Attachment 8 1.7 Unified Compliance/Conformance Matrix for)

IEEE Stds 603-1991 and 7-4.3.2-2003 (see D.6)

Addressed in LTR, Section 7, "PPS - Compliance/Conformance Matrix for IEEE Standards 603-1991 and 7-4.3.2-2003" 1.8 Changes to Technical Specifications (see D.7)

LAR, Attachment 2 1.9 Setpoint Methodology and Calculations (see D.7)

Not applicable; There are no changes to setpoints, setpoint calculations, or setpoint methodology.

1.10 Secure Development and Operational Environment (see D.8)

Addressed in LTR, Section 8, "PPS - Secure Development and Operational Environment (D.8)

  • Post LAR submittal Supplements will include the following:

- Equipment Qualification

  • Equipment Qualification Summary Report (EQSR), as needed
  • Seismic EQ
  • Environmental EQ

- HFE NUREG-0711 Result Summary Reports (RSRs) (Procedure / Training Impacts, V&V)

- System Design Specification (SyDS), Revision 2

  • Separate Risk-Informed Completion Time (RICT) LAR
  • Separate Installation Support LAR Post LAR Supplements / Submittals 11

12 Vendor Oversight Plan /

VOP Summary

  • The VOP has been established as a controlled CEG procedure; it is a procedure-based umbrella document that implements the CEG vendor oversight activities
  • The hierarchy of CEG procedures that will ensure the effectiveness of CEG vendor oversight activities is described in both the VOP and VOP Summary

- Quality management, procurement, design control, project management, risk management, and corrective action

  • Performance measures and acceptance criteria for each phase of the software life cycle are included in the VOP and described in the VOP Summary
  • Corrective action and documentation processes for CEGs vendor oversight activities are included in the VOP and summarized in the VOP Summary
  • Both the VOP and VOP Summary include a description of the administrative process for revising the oversight plan 13 Vendor Oversight Plan
  • Background
  • VOP Table of Contents
  • Vendor Oversight Plan Scope
  • Procedural Basis for the VOP

- Quality Management

- Procurement

- Design Control

- Project Management

- Risk Management

- Corrective Action

- VOP Change Process

  • Project Organization and Roles
  • Performance Measures and Acceptance Criteria
  • Plant Specific Action Items
  • Corrective Actions 14 Vendor Oversight Plan Summary

15 HFE Follow-up from June 2022 Presubmittal Meeting

Key HFE Requirements UFSAR Section 13.1.2 / NUREG-0737 Supplement 1, Item I.D.1 DCRDR Program Plan and Summary Report Key HFE Guidance DI&C-ISG-06 DI&C-ISG-06 references NUREG-0711, NUREG-1764, IEEE 603-1991 Key Limerick Documents Demonstrating Compliance INL/LTD-22-68693, HFE Program Plan LAR Attachment 10, Table 1 maps the relevant HFE Program Plan sections to the requirements in NUREG-0737 Supplement 1 Item I.D.1 (DCRDR) requirements The HFE Program Plan describes how all 12 NUREG-0711 HFE activities are implemented for the project The HFE program plan addresses how NUREG-1764 is used Licensing Basis will be updated to include NUREG-0711 and NUREG-1764 as part of this modification 16 Addressing HFE Regulatory Requirements and Guidance

17 V&V Results Timing Date Activity Results Available for Draft SER 12/9/2022 2/9/2023 Report Execute Conceptual Verification (CV) and generate report Yes 2/17/2023 3/30/2023 Report Execute Preliminary Validation (PV) and issue report Yes 8/31/2023 12/22/2023 Report Execute ISV and generate report No 12/22/2023 2/23/2024 Report Execute FAT, resolve any relevant issues from ISV and generate FAT report.

No

18 V&V Information to Support LAR in Lieu of Final ISV Activity Description Product Equipment Used for Activity CV Verifies the conceptual design against style guide via scenario walkthroughs Uses prototype static displays and navigation strategy created as part of Task Analysis (TA)

Uses draft procedures aligned with prototype displays Important Human Actions are assessed CV results included in Report Combination of laptop loaded with static displays, and/or glass top simulator PV Uses dynamic displays Validates procedures and HSI design Conducted via a dynamic HSI workshop Follows the Preliminary Validation per NUREG-0800, Chapter 18, Attachment A.

will address any changes to credited manual actions.

PV results included in RSR with the Task Support Verification (TSV)

Any combination of laptop, ANSI 3.5 simulator, and/or glass top simulator

  • Glass Top Simulator (used for PV)

- Stand-alone unit that represents the control room on digital touch screens.

- Includes three or four screens on a roll-around unit.

- Can represent the control room on a digital screen for any given configuration but will not include the physical HSIs.

- Screen size is constrained and, therefore, may not reflect actual HSI sizes.

- Only displays parts of the control room at any given time.

- Uses physical HSIs.

- Physical modifications are put in place by disabling HSIs (switches, screens, etc.) and mounting temporary interfaces.

- May not fully represent the final control room configuration

- Positioning of the HSIs may not exactly correspond to their final location.

- Provides the ability to see the entire control room at the same time.

19 Glass Top Simulator & ANSI 3.5 Simulator

20 Elimination of Turbine Enclosure - Main Steam Line Tunnel Temperature - High Isolation Function

  • The ambient temperature of the monitored Turbine Enclosure (TE) Main Steam Line (MSL) tunnel area can approach the automatic isolation setpoint for reasons other than actual main steam leaks in the area, such as hot weather, reduced efficiency of the TE chillers, or instrument drift.
  • If both TE MSL Tunnel Temperature - High trip systems were to initiate an isolation signal, a full Group 1 isolation and reactor trip would result. Group 1 isolation closes the MSIVs, resulting in a loss of heat sink, as well as rendering the main feedwater system unavailable for scram recovery. The loss of Feed Water becomes a scram with complications.
  • The proposed change deletes CTS 3.3.2 Function 1.g, Turbine Enclosure (TE)

- Main Steam Line (MSL) Tunnel Temperature - High, from CTS Tables:

3.3.2-1, Isolation Actuation Instrumentation 3.3.2-2, Isolation Actuation Instrumentation Setpoints 3.3.2-3, Isolation Actuation Instrumentation Response Times 4.3.2.1-1, Isolation Actuation Instrumentation Surveillance Requirements.

21 Elimination of Turbine Enclosure - MSL Tunnel Temperature - High Isolation Function

  • The proposed change adds new TS 3.7.9, Turbine Enclosure Main Steam Line Tunnel Temperature. Proposed TS 3.7.9 will ensure that an MSL steam leak in the TE MSL tunnel will be promptly detected, and appropriate actions taken.
  • The new LCO 3.7.9 is applicable in OPCON 1, 2, and 3 and requires the TS MSL Tunnel maximum temperature to be 175°F (i.e., current isolation trip setpoint).
  • New SR 3.7.9.1 requires verification that the TE MSL tunnel temperature is 175°F on a frequency controlled by the Surveillance Frequency Control Program (SFCP). The initial frequency will be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
  • Proposed Actions require immediate verification that no MSL leak exists if TE MSL Tunnel temperature exceeds 175°F, and periodic verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. If it cannot be verified that there is no MSL leakage, or if the periodic verification is not performed, a plant shutdown is required.

22 Elimination of Turbine Enclosure - MSL Tunnel Temperature - High Isolation Function (cont.)

  • The TE - MSL Tunnel Temperature - High function is not assumed to actuate in any accident analysis. The function is a surrogate for MSL leakage, which is an assumption in some accident analyses. However, creating the potential for a complicated reactor scram based on a surrogate indication, which may not be indicative of actual MSL leakage, is unnecessary.
  • Replacing this automatic MSIV isolation requirement with a monitoring requirement and a manual shutdown if MSL leakage is detected will eliminate the risk of an unnecessary plant transient while still providing the appropriate remedial actions to ensure the plant is operating safely and within the assumed plant conditions.
  • The proposed change is similar to May 20, 2022 Hatch license amendment precedent that eliminated the Hatch instrumentation function, Turbine Building Area Temperature - High. This Hatch function serves the same purpose as the LGS "Turbine Enclosure Main Steam Line Tunnel Temperature," function.

23 Elimination of Turbine Enclosure - MSL Tunnel Temperature - High Isolation Function (cont.)

24 Implementation LAR Overview

  • Add a note to the Operational Condition (MODE) 5 Applicability of TS 3/4.3.1, "Reactor Protection System Instrumentation," Tables 3.3.1.1-1 and 4.3.1.1-1, Function 11, "Reactor Mode Switch Shutdown Position," and Function 12 "Manual Scram," consistent with NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants," Revision 5.0;
  • Add a one-time Completion Time (CT) extension for TS 3/4.3.4, "ATWS Recirculation Pump Trip Actuation Instrumentation," Actions d. and e.

25 INSTALLATION Support LAR

  • Add a one-time Completion Time (CT) extension for TS 3/4.3.4, "ATWS Recirculation Pump Trip Actuation Instrumentation," Actions d. and e.
  • LCO 3.3.4.1 Action d: With one trip system inoperable, restore the inoperable trip system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or in accordance with the Risk Informed Completion Time Program, or be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
  • LCO 3.3.4.1 Action e: With both trip systems inoperable, restore at least one trip system to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least STARTUP within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
  • Requesting CT extension to 30 days to support simultaneous demolition of both Trip systems planned to start 30 days prior to Refuel Outage.
  • Demolition of one trip system at a time was reviewed and judged not practical.
  • Note in the PPS submittal (9/30/22) the RRCS system will be reclassified as a non-safety related system, removed from TS, and implemented on the non-safety relation Ovation Platform.
  • The justification will be based on a hybrid technical justification using both deterministic and risk insights.
  • A PRA analysis was completed that meets RG 1.177 thresholds for one time CT extensions.

26 INSTALLATION Support LAR

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