ML23032A244

Regulatory Audit Plan for Review of Human Factors Engineering Portion of Limerick Digital Instrumentation and Controls License Amendment Request

ML23032A244
Person / Time
Site:	Limerick
Issue date:	02/06/2023
From:	Marshall M Plant Licensing Branch 1
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
EPID L-2022-LLA-0140
Download: ML23032A244 (1)

Text

February 6, 2023 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:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - REGULATORY AUDIT PLAN FOR REVIEW OF HUMAN FACTORS ENGINEERING PORTION OF LIMERICK DIGITAL INSTRUMENTATION AND CONTROLS LICENSE AMENDMENT REQUEST (EPID L-2022-LLA-0140)

Dear Mr. Rhoades:

By letter dated September 26, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22269A569), as supplemented by letters dated August 12, 2022 (ML22224A149), and November 29, 2022 (ML22333A817), Constellation Energy Generation, LLC (Constellation, licensee), submitted license amendment requests for Limerick Generation Station, Units 1 and 2 (Limerick). The proposed amendment requests would change both the design and technical specifications to permit the use of a new single digital instrumentation and controls system to replace analog instrumentation of reactor protection system, analog nuclear steam supply shutoff system, emergency core cooling system, reactor core isolation cooling system, and end-of-cycle recirculation pump trip at Limerick. In addition, the proposed amendments would change the classification of the redundant reactivity control system from safety-related to non-safety-related, eliminate the automatic redundant reactivity control system feedwater runback function, eliminate the automatic isolation function for the turbine enclosure main steam line tunnel temperature high indication, eliminate several surveillance requirements, and allow the use of automated operator aids (or automated controls) from main control room.

The NRC staff has determined that a regulatory audit is needed to assist in the review of the Limerick digital instrumentation and controls license amendment request. The audit will be conducted in two parts and will start on February 21, 2023, at Idaho National Laboratory. The end of the audit will depend on the licensees schedule for conducting integrated system validation activities. Additional details for the audit are in the enclosed audit plan.

D. Rhoades If you have any questions, please contact me by telephone at 301-415-2871 or by e-mail to michael.marshall@nrc.gov or Bhagwat BP Jain by telephone at 301-415-6303 or by e-mail to bhagwat.jain@nrc.gov.

Sincerely,

/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:

Audit Plan cc: Listserv

ML23032A244 OFFICE DORL/LPL1/PM DORL/LPL1/LA DRO/IOLB/BC DORL/LPL1/BC NAME MMarshall KZeleznock LNist (BGreen for) HGonzález DATE 01/31/2023 02/06/2023 01/31/2023 02/06/2023 OFFICE DORL/LPL1/PM NAME MMarshall DATE 02/06/2023 AUDIT PLAN FOR HUMAN FACTORS ENGINEERING PORTION OF LIMERICK DIGITAL INSTRUMENTATION AND CONTROLS LICENSE AMENDMENT REQUEST CONSTELLATION ENERGY GENERATION, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353

1.0 BACKGROUND

By letter dated September 26, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22269A569), as supplemented by letters dated August 12, 2022 (ML22224A149), and November 29, 2022 (ML22333A817), Constellation Energy Generation, LLC (Constellation, licensee), submitted license amendment requests for Limerick Generation Station, Units 1 and 2 (Limerick). The proposed amendment requests would change both the design and technical specifications to permit the use of a new single digital instrumentation and controls (I&C) system to replace analog instrumentation of reactor protection system, analog nuclear steam supply shutoff system, emergency core cooling system, reactor core isolation cooling system, and end-of-cycle recirculation pump trip at Limerick. In addition, the proposed amendments would change the classification of the redundant reactivity control system from safety-related to non-safety-related, eliminate the automatic redundant reactivity control system feedwater runback function, eliminate the automatic isolation function for the turbine enclosure main steam line tunnel temperature high indication, eliminate several surveillance requirements, and allow the use of automated operator aids (or automated controls) from main control room.

The NRC staff has determined that a regulatory audit is needed to assist in the review of the Limerick digital I&C license amendment request.

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 to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated Attachment

October 2019 (ML19226A274). This audit is being conducted to support the NRC staffs review of the Limerick digital I&C license amendment request. It should be noted that this audit is in addition to the ongoing open item audit being conducted remotely.

3.0 PURPOSE AND SCOPE The purpose of the audit is to gain a more detailed understanding of the human factors engineering portion of Constellations Limerick digital I&C license amendment request.

Specifically, the audit team will be observing licensees validation activities. The NRC staff plan to:

Gain a clear understanding of the proposed control room changes, including the differences between the old human system interface and the proposed human system interface.

Gain an understanding of the limitations associated with testbed, including the capabilities of the glasstop simulator, as well as any known deviations from the actual simulator/control room.

Gain an understanding of any early design issues, including any discovered human engineering discrepancies and tracking, prioritization, and resolution of issues.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT Please upload the following documentation by February 17, 2023, to the online portal used by Constellation to support the ongoing open items audits:

If available, any training materials/outlines or plans for updating training programs.

If available, any preliminary plans/procedures for the licensees approach to verification and validation.

If possible, please segregate these documents from the documents uploaded to support the open items audit.

5.0 AUDIT TEAM The members of the audit team are:

Kamishan Martin, Human Factors Engineer and Audit Team Lead Brian Green, Human Factors Engineering Team Lead Jesse Seymour, Senior Reactor Engineer Michael Marshall, Senior Project Manager

6.0 LOGISTICS The audit will be conducted in two parts. The first part of the audit of licensees preliminary validation activities will start on February 21 and end on February 23, 2023. The first part of the audit will be conducted at the Idaho National Laboratory. The second part of the audit of licensees integrated system validation activities is tentatively scheduled August 2023. The location of the second part of the audit is to be determined.

The audit team will not remove any non-docketed documents or other materials from the online portal or location of the audit. If the audit team identifies information that requires docketing to support the basis for a regulatory decision concerning the review of the Limerick digital I&C license amendment request, the NRC staff will use the request for additional information process.

Any changes in the audit logistics will be coordinated and communicated through the assigned NRC project manager.

7.0 SPECIAL REQUEST If available, please provide the audit team with a small, enclosed conference room or similar space for the audit teams use and access to guest wi-fi.

8.0 DELIVERABLES An audit summary, which may be public, will be prepared within 90 days of the completion of the second part of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue requests for additional information to the licensee.