ML23089A324

Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System Human Factors Engine

ML23089A324
Person / Time
Site:	Limerick
Issue date:	03/30/2023
From:	David Helker Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23089A323	List: ML23089A324
References
Download: ML23089A324 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com ATTACHMENT TRANSMITTED HEREWITH MAY CONTAIN INFORMATION CONTROLLED BY THE DEPARTMENT OF ENERGY UNDER ITS REGULATIONS at 10 CFR PART 810.

ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ATTACHMENT TRANSMITTED HEREWITH MAY CONTAIN INFORMATION CONTROLLED BY THE DEPARTMENT OF ENERGY UNDER ITS REGULATIONS at 10 CFR PART 810 and CONTAINS PROPRIETARY INFORMATION.

When separated, the cover letter is decontrolled.

10 CFR 50.90 March 30, 2023 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Document Control Desk 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:

Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS)-

Human Factors Engineering Preliminary Validation Results Summary Report

References:

1. Constellation Energy Generation, LLC (CEG) letter to the U.S. Nuclear Regulatory Commission (NRC), "License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS)," dated September 26, 2022 (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML22269A5690).

2. U.S. Nuclear Regulatory Commission (NRC) letter to Constellation Energy Generation, LLC (CEG), Limerick Generation Station, Unit Nos. 1 and 2 -

Acceptance of Requested Licensing Action Re: Replacement of Existing Safety Related Analog Control Systems with a Single Digital Plant Protection System (EPID L-2022-LLA-0140), dated December 9, 2022 (ADAMS Accession No. ML22339A064).

In accordance with 10 CFR 50.90, Constellation Energy Generation, LLC (CEG) requested a License Amendment Request (LAR) to replace the Limerick Generating Station, Units 1

Supplemental HFE PV RSR Docket Nos. 50-352 and 50-353 March 30, 2023 Page 2 ATTACHMENT TRANSMITTED HEREWITH MAY CONTAIN INFORMATION CONTROLLED BY THE DEPARTMENT OF ENERGY UNDER ITS REGULATIONS at 10 CFR PART 810.

ATTACHMENT TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 and 2 existing safety-related analog control systems with a single digital Plant Protection System (PPS) (Reference 1). NRC accepted the LAR for review on December 9, 2022 (Reference 2).

In Reference 1, CEG described supplemental information that needed to be updated at a later time. In Reference 2, NRC acknowledged a schedule for required supplemental information. Accordingly, CEG is providing the Human Factors Engineering Preliminary Validation Results Summary Report (HFE PV RSR) in the Attachment to this letter. The attached report is classified by the Department of Energy (DOE) as Official Use Only (OUO), Exemption Class 3, Export-Controlled Information, and Exemption Class 4, Commercial/Proprietary and is to be considered exempt from public release under 10 CFR 2.390.

This letter does not contain the typical redacted non-proprietary version of the HFE PV RSR and proprietary affidavits normally associated with a 10 CFR 2.390 withholding request. The preparation of the non-proprietary version of attached HFE PV RSR has been delayed due to resource restraints and will be submitted within a few weeks. The Limerick Digital Modernization Project has decided to keep the current NRC review on schedule by providing the necessary HFE required information by the due date agreed to in Reference 2 to support timely NRC Safety Evaluation development.

This supplemental letter contains no regulatory commitments.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), CEG is notifying the Commonwealth of Pennsylvania of this supplemental letter by transmitting a copy of this letter to the designated State Official.

If you have any questions regarding this submittal, then please contact Frank Mascitelli at Francis.Mascitelli@constellation.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 30th day of March 2023.

Respectfully, David P. Helker Sr. Manager - Licensing Constellation Energy Generation, LLC

Supplemental HFE PV RSR Docket Nos. 50-352 and 50-353 March 30, 2023 Page 3 ATTACHMENT TRANSMITTED HEREWITH MAY CONTAIN INFORMATION CONTROLLED BY THE DEPARTMENT OF ENERGY UNDER ITS REGULATIONS at 10 CFR PART 810.

ATTACHMENT TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390

Attachment:

NL/RPT-23-71903, Limerick Safety-Related Instrumentation and Controls Upgrade, Human Factors Engineering Preliminary Validation Report, dated March 2023. (Proprietary) cc:

USNRC Region I, Regional Administrator w/ attachment USNRC Project Manager, LGS USNRC Senior Resident Inspector, LGS Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection w/o attachment