ML23325A206

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

ML23325A206
Person / Time
Site:	Limerick
Issue date:	11/21/2023
From:	David Helker Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23325A204	List: ML23325A206
References
Download: ML23325A206 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 November 21, 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)-

Qualification Summary Report Rev 1

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 letter to U.S. Nuclear Regulatory Commission, 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, dated May 23, 2023 (ADAMS Accession No. ML23143A342)

ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390.

When separated, the cover letter is decontrolled.

DMP LAR Supplement for Qualification Summary Report Rev 1 Docket Nos. 50-352 and 50-353 November 21, 2023 Page 2 ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 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 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 3, CEG communicated to NRC that the Digital Modernization Project would pivot to the Unit 2 2025 Spring Refueling Outage for first installation of the new Plant Protection System (PPS). The Reference 3 submittal letter contained a revised schedule of post-LAR supplements based on the pivot to the Unit 2 installation. Accordingly, this submittal transmits the following document:

• Qualification Summary Report (Revision 1)

In Reference 3, CEG communicated that it would submit three separate environmental qualification (EQ) summary reports. Due to delays in manufacturing and EQ testing, and to facilitate the compressed testing schedule, CEG has decided to issue one EQ summary report that would be updated as each separate EQ testing topic (seismic, environmental and EMC) was completed. Hence, the NRC should expect multiple resubmittals of the same document, EQ-QR-433-GLIM. Note that the current environmental and EMC testing sections are annotated to be prepared later with appropriate open item tracking numbers. contains the Westinghouse Electric Company (WEC) proprietary EQ-QR-433-GLIM, Revision 1 (updated to include a summary of the seismic testing results only). contains the WEC proprietary affidavit, CAW-23-045 for Attachment 1. contains an affidavit signed by WEC, the owner of the proprietary information.

The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the NRC, and it addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the NRCs regulations. WEC requests that the WEC proprietary information contained in Attachment 1 be withheld from public disclosure in accordance with 10 CFR 2.390. Future correspondence with respect to the proprietary aspects of the application for withholding related to WEC proprietary information or the WEC affidavit provided in the applicable attachment should reference this request letter.

CEG has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, which was previously provided to the NRC in the Reference 1 letter. CEG has concluded that the information provided in this supplemental letter does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92. In addition, CEG has concluded that the information in this supplemental letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendments.

DMP LAR Supplement for Qualification Summary Report Rev 1 Docket Nos. 50-352 and 50-353 November 21, 2023 Page 3 ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 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 Ashley Rickey at Ashley.Rickey@constellation.com or Frank Mascitelli at Francis.Mascitelli@constellation.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 21st day of November 2023.

Respectfully, David P. Helker Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments: 1. Qualification Summary Report for the Plant Protection System Upgrade for Limerick Units 1 & 2, EQ-QR-433-GLIM, Rev. 1, dated November 2023

2. WEC Affidavit CAW-23-045 for EQ-QR-433-GLIM, Rev. 1 cc: USNRC Region I, Regional Administrator w/ attachments USNRC Project Manager, LGS "

USNRC Senior Resident Inspector, LGS "

Director, Bureau of Radiation Protection - Pennsylvania w/o attachments Department of Environmental Protection

Attachment 1 License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 Qualification Summary Report for the Plant Protection System Upgrade for Limerick Units 1 & 2 EQ-QR-433-GLIM, Rev. 1, dated November 2023 (Proprietary)

Attachment 2 License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 WEC Affidavit CAW-23-045 for EQ-QR-433-GLIM, Rev. 1

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-23-045 Page 1 of 2 Commonwealth of Pennsylvania:

County of Butler:

(1) I, Zachary Harper, Senior Manager, Licensing Engineering, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting EQ-QR-433-GLIM, Revision 1 be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

(ii) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

• • • This record was final approved on 11/20/2023 15:26:20. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-23-045 Page 2 of 2 (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached submittal contains proprietary information throughout, for the reasons set forth in Sections (5) (a) and (c) of this Affidavit. Accordingly, a redacted version would be of no value to the public.

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 11/20/2023 _____________________________

Signed electronically by Zachary Harper

• • • This record was final approved on 11/20/2023 15:26:20. (This statement was added by the PRIME system upon its validation)

CAW-23-045 Revision 0 Non-Proprietary Class 3

• • This page was added to the quality record by the PRIME system upon its validation and shall not be considered in the page numbering of this document.**

Approval Information Manager Approval Harper Zachary S Nov-20-2023 15:26:20 Files approved on Nov-20-2023

• • • This record was final approved on 11/20/2023 15:26:20. (This statement was added by the PRIME system upon its validation)