Letter Sequence Supplement |
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EPID:L-2022-LLA-0140, Review of Limerick Generating Station Defense in Depth and Diversity Common Cause Failure Coping Analysis, WNA-AR-01074-GLIM-P, Rev 1. Without Attachment 3 Enclosure (Open) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance, Acceptance, Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
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MONTHYEARML22046A0742022-02-14014 February 2022
Review of Limerick Generating Station Defense in Depth and Diversity Common Cause Failure Coping Analysis, WNA-AR-01074-GLIM-P, Rev 1. Without Attachment 3 Enclosure
Project stage: Request
PMNS20220709, Meeting Between NRC Staff and Constellation Energy Generation, LLC on the Review of the Defense-in-Depth and Diversity Coping Analysis Supporting the Digital Upgrade of Instrumentation and Controls at Limerick Generating Station, Units2022-07-22022 July 2022
Meeting Between NRC Staff and Constellation Energy Generation, LLC on the Review of the Defense-in-Depth and Diversity Coping Analysis Supporting the Digital Upgrade of Instrumentation and Controls at Limerick Generating Station, Units 1 an
Project stage: Request
ML22224A1492022-08-15015 August 2022
Review of Limerick Generating Station Defense in Depth and Diversity Common Cause Failure Coping Analysis, WNA-AR-01074-GLIM-P, Revision 2, July 2022, and the Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital
Project stage: Request
PMNS20221157, Meeting Between NRC and Constellation Energy Generation, LLC Regarding Ongoing Acceptance Review of Limerick Generating Station, Units 1 and 2 Digital Instrumentation and Controls License Amendment Request2022-11-0707 November 2022
Meeting Between NRC and Constellation Energy Generation, LLC Regarding Ongoing Acceptance Review of Limerick Generating Station, Units 1 and 2 Digital Instrumentation and Controls License Amendment Request
Project stage: Acceptance Review
ML23009A5622022-11-0707 November 2022, 14 November 2022, 11 January 2023
Summary of December 15, 2022 Public Meeting on Limeric Digital I&C LAR Acceptance
Project stage: Request
ML22312A4402022-11-10010 November 2022
Public Meeting with Constellation About Acceptance Review: Status of NRC Staffs Acceptance Review of the Limerick Digital Instrumentation and Controls License Amendment Request
Project stage: Acceptance Review
ML22340A2172022-11-10010 November 2022, 21 November 2022, 6 December 2022
Summary of November 10, 2022, Meeting with Constellation Energy Generation, Lic on Acceptance Review of Limerick Digital Instrumentation and Controls License Amendment Requests
Project stage: Request
ML22319A0012022-11-14014 November 2022
Constellation Energy Generation, LLCs Presentation for November 10, 2022 Public Meeting with NRC
Project stage: Request
ML22320A1132022-11-21021 November 2022
Generation Station, Units 1 and 2 - Supplemental Information Needed for Acceptance of Digital Instrumentation and Controls License Amendment Requests
Project stage: Acceptance Review
ML22333A8172022-11-29029 November 2022
Response to Supplemental Information Needed for Acceptance of Digital Instrumentation and Controls License Amendment Requests for the Limerick Generating Station
Project stage: Supplement
ML22327A0192022-12-0606 December 2022
Summary of November 10, 2022, Meeting with Constellation Energy Generation, Lic on Acceptance Review of Limerick Digital Instrumentation and Controls License Amendment Requests
Project stage: Acceptance Review
ML22339A0642022-12-0909 December 2022
Generation Station, Unit Nos. 1 and 2 – Acceptance of Requested Licensing Action Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System
Project stage: Acceptance Review
ML22347A1532022-12-13013 December 2022
Public Meeting Presentation, December 15, 2022 Di&C License Amendment Request
Project stage: Meeting
ML23003A1702022-12-15015 December 2022
Official Transcript of the 12/15/22 Meeting with Constellation Energy to Discuss the Exceptions Described for the Independence and Operating Bypass with IEEE 603 of the Proposed Plant Protection System in the Limerick Station, Units 1 and 2
Project stage: Meeting
ML23009A5872023-01-11011 January 2023
Summary of December 15, 2022, Meeting with Constellation Energy Generation, LLC on Potential Compliance with Certain Clauses of IEEE Standard 603-1991 in Limerick Digital Instrumentation and Controls License Amendment Requests
Project stage: Meeting
ML22353A6322023-01-17017 January 2023
Supplement to Regulatory Audit Plan in Support of Review of Digital I&C Upgrade to Protection Systems (EPID L-2022-LLA-0140) - Non-Proprietary
Project stage: Other
PMNS20230026, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-01-20020 January 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23076A1062023-01-20020 January 2023, 12 May 2023
Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
ML23032A2442023-02-0606 February 2023
Regulatory Audit Plan for Review of Human Factors Engineering Portion of Limerick Digital Instrumentation and Controls License Amendment Request
Project stage: Other
ML23039A1412023-02-0808 February 2023
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
Project stage: Supplement
ML23046A2662023-02-15015 February 2023
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
Project stage: Supplement
PMNS20230032, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-02-23023 February 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
PMNS20230033, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-03-0606 March 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23121A0042023-03-0606 March 2023, 12 May 2023
Summary of March 29, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
ML23118A3792023-03-17017 March 2023, 9 June 2023
April 12, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
PMNS20230254, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-03-17017 March 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23089A3242023-03-30030 March 2023
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
Project stage: Supplement
ML23095A2232023-04-0505 April 2023
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
Project stage: Supplement
ML23132A3092023-04-17017 April 2023, 18 May 2023
Summary of May 3, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
PMNS20230423, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-04-17017 April 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23121A0022023-05-12012 May 2023
Summary of March 29, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23076A1042023-05-12012 May 2023
Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23076A0132023-05-12012 May 2023
March 15, 2023, Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23145A0672023-05-15015 May 2023, 31 May 2023
May 17, 2023, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
PMNS20230627, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-05-15015 May 2023
Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23156A4172023-05-16016 May 2023, 9 June 2023
Summary of May 24, 2023, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
PMNS20230606, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-05-16016 May 2023
Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23132A3082023-05-18018 May 2023
Summary of May 3, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23143A3422023-05-23023 May 2023
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
Project stage: Supplement
ML23145A0352023-05-31031 May 2023
Summary of May 17, 2023, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23118A3752023-06-0909 June 2023
Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23156A2472023-06-0909 June 2023
Summary of Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23177A2242023-06-26026 June 2023
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 .
Project stage: Supplement
PMNS20230846, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-07-18018 July 2023
Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23187A0962023-07-19019 July 2023
Generation Station, Unit Nos. 1 and 2 - Revised Estimated Review Completion Date Concerning License Amendment Request to Replace Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System
Project stage: Other
2023-02-23
[Table View] |
Text
Constellation~
200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnerqy.com 10 CFR 50.90 May 23, 2023 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Document Control Desk
Subject:
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 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) -
Pivot to Unit 2 First Installation
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).
- 3. Constellation Energy Generation, LLC (CEG) letter to the NRC, "License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 1 0CFR50.62 A TWS Rule to Support the Digital Modernization Project Installation," dated February 17, 2023 (ADAMS Accession No. ML23048A313).
Per Reference 1 and in accordance with 10 CFR 50.90, Constellation Energy Generation, LLC (CEG) requested amendments to Renewed Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. The proposed changes would revise the LGS licensing and design basis to incorporate a planned digital modification at LGS (i.e., the LGS Digital Modernization Project).
Supplement to License Amendment Request Limerick Digital Modernization Project Docket Nos. 50-352 and 50-353 May 23, 2023 Page 2 The LGS Digital Modernization Project (DMP) will replace the existing analog control logic hardware of the Reactor Protection System (RPS) instrumentation, Nuclear Steam Supply Shutoff System (NSSSS) instrumentation, the Emergency Core Cooling System (ECCS) instrumentation, the Reactor Core Isolation Cooling (RCIC) System instrumentation, and the End-of-Cycle Recirculation Pump Trip (EOC-RPT) instrumentation with a new, single, digital control system. The new, single, digital control system (i.e., for RPS, NSSSS, ECCS, RCIC, and EOC-RPT) will be renamed the Plant Protection System (PPS).
In Reference 1, CEG communicated plans to implement the LGS DMP during the LGS Unit 1 20th refueling outage (Li1 R20) and LGS Unit 2 18th refueling outage (Li2R 18), currently scheduled to commence in April 2024 and April 2025, respectively. CEG requested approval of the proposed license amendments by March 1, 2024 (i.e., 15 months following a two-month acceptance review). The proposed TS changes would be implemented prior to start-up from the Li 1 R20 and Li2R 18 refueling outages.
In Reference 2, NRC provided their acceptance of the license amendment request (LAR) for further NRC review. Based on the information provided in the LAR, including the schedule for when supplemental information would be provided, the NRC staff estimated that this LAR would take approximately 7000 hours0.081 days <br />1.944 hours <br />0.0116 weeks <br />0.00266 months <br /> to complete. The NRC staff expected to complete this review by March 11, 2024. That completion date would have supported installation of the new PPS during the Unit 1 2024 Refuel Outage starting in April 2024.
Subsequent to the LAR NRC Acceptance Review, the final design activities for the PPS have been delayed due to additional design refinement iterations with the system Original Equipment Manufacturer. CEG has concluded that it is no longer possible to have the design completed and equipment ready in time to support the Unit 1 installation during the April 2024 Refuel Outage. Therefore, CEG is pivoting final design and project activities to support the first installation of the PPS on Unit 2 during its planned April 2025 Refuel Outage.
During the Acceptance Review Process, CEG indicated that the following documents associated with the LAR would be submitted on the specified dates. An update to that schedule follows and additional LAR supplements are identified in the table below.
DMP LAR Supplemental Information Date of Planned Submittal APP-GW-GLR-611, Rev. 3, "ITAAC 2.5.02.14: Component Interface July 31, 2023 Module Desian Process Technical Report" WCAP-16097-P Appendix 5, Revision 6, "Common Qualified Platform" July 31, 2023 D-3 Coping Analysis (Revision 3) Submittal July 31, 2023 VOP Summary (Revision 1) Submittal July 31, 2023 SyRS (Revision 2) Submittal August 31, 2023
Supplement to License Amendment Request Limerick Digital Modernization Project Docket Nos. 50-352 and 50-353 May 23, 2023 Page 3 SyDS (Revision 4) Submittal FMEA (Revision 1) Submittal LAR Attachment 1 (Revision 1) Submittal L TR (Revision 1) Submittal Seismic Equipment Qualification Summary Report, Revision 0 Environmental Equipment Qualification Summary Report, Revision 1 Electromagnetic Compatibility Equipment Qualification Summary Report, Revision 2 August 31, 2023 August 31, 2023 August 31, 2023 September 15, 2023 November 22, 2023 January 24, 2024 January 24, 2024 Note for the SyRS and SyDS revisions, we will evaluate whether the changes are significant enough to affect the LAR, and if so, will plan to submit them in the late August 2023 time frame. The L TR planned submittal date assumes the LAR Audit Open Item Process regarding L TR concerns will be mostly completed near the proposed submittal date.
In addition, the DMP Installation Support LAR (Reference 3) will need to be supplemented because the original refueling outage dates are embedded in the proposed Unit 1 Technical Specification Markups and will need to be updated to reflect the new outage installation schedule. This supplement is expected to be submitted by July 31, 2023.
CEG now plans to implement the LGS DMP during the LGS Unit 2 refueling outage (Li2R18) and LGS Unit 1 refueling outage (Li1 R21 ), currently scheduled to commence in April 2025 and April 2026, respectively. CEG understands that the original NRC review timeline presented during the Acceptance Review will need to be modified. CEG respectfully requests approval of the proposed license amendments as soon as possible after the original March 11, 2024 date. We also request that the NRC inform us of the impact to the original NRC review time and cost estimates associated with the project moving the first installation to Unit 2 in April 2025.
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 LAR supplemental letter by transmitting a copy of this letter to the designated State Official.
If you have any questions regarding this submittal, please contact Frank Mascitelli at Frank. Mascitelli@constellation.com.
Supplement to License Amendment Request Limerick Digital Modernization Project Docket Nos. 50-352 and 50-353 May 23, 2023 Page 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on this 23rd day of May 2023.
Respectfully, David P. Helker Sr. Manager - Licensing Constellation Energy Generation, LLC cc:
USNRC Region I, Regional Administrator USNRC Project Manager, LGS USNRC Senior Resident Inspector, LGS Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection II II
