ML24026A292

– Request for Additional Information Regarding Limerick Digital Instrumentation and Controls License Amendment Request

ML24026A292
Person / Time
Site:	Limerick
Issue date:	01/26/2024
From:	Marshall M Plant Licensing Branch 1
To:	Ashley R, Mascitelli F Constellation Energy Generation
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
EPID L-2022-LLA-0140
Download: ML24026A292 (1)

Text

From: Michael Marshall To: [Licensee] Frank Mascitelli (Constellation Nuclear); Rickey, Ashley:(Constellation Nuclear)

Subject:

Limerick Generating Station, Units 1 and 2 - Request for Additional Information Regarding Limerick Digital Instrumentation and Controls License amendment Request (EPID L-2022-LLA-0140)

Date: Friday, January 26, 2024 12:08:00 PM

Hello Frank and Ashley,

By letter dated September26, 2023 (Agencywide Documents Access and Management System Accession No. ML22269A569; non-public), as supplemented by letters dated August12, 2022 (ML22224A149), November29, 2022 (ML22333A817),

February8, 2023 (ML23039A141), February15, 2023 (ML23046A266), March30, 2023 (ML23089A324), April5, 2023 (ML23095A223), June26, 2023 (ML23177A224),

July31, 2023 (ML23212B236), September12, 2023 (ML23255A095), October30, 2023 (ML23303A223), and November21, 2023 (ML23325A206). The supplement dated September12, 2023 replaces in its entirety the original license amendment request dated September26, 2023. The Licensee replaced the original submittal, because it had mistakenly included proprietary information in the non-proprietary parts of the request. The original submittal was made non-public by the U.S. Nuclear Regulatory Commission (NRC) staff, because of the mistaken inclusion of proprietary information by the Licensee. With the exceptions noted by the Licensee in the letter dated September26, 2023, the content of the replacement and the original are the same.

The proposed amendment requests would change both the design and technical specifications to permit the use of a new single digital instrumentation and controls (DI&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 reviewed the information provided in the license amendment request and has determined that additional information is needed to complete its review. This request for additional information was discussed with you on January 19 and 26, 2024, and it was agreed that your response would be provided within 30 days of the date of this email for requests for additional information (RAIs) 1, 2, and 3 and within 45 days of the date of the email for RAI 4. The RAIs that have some relationship to an audit question(s) that was asked during the open item audit are indicated with the audit question identifier at the beginning of the RAI.

The NRCs review is ongoing and additional RAIs, if any, will be provided in separate correspondence.

RAIs

1. (OI-56 and OI-78) In Table 3.2.5-1, DI&C-ISG-04, Section 2 Compliance, and Table 3.2.21-1, DI&C-ISG-04, Compliance, of the Licensing Technical Report (LTR) attached to the letter dated August 12, 2022, the Licensee describes how the component interface module (CIM) addresses applicable positions on Command Prioritization in Section 2 of DI&C Interim Staff Guidance (ISG) 04, Highly Integrated Control Rooms - Communications Issues. In Tables 3.2.5-1 and 3.2.21-1 of the LTR included with the letter dated August 12, 2022, Constellation uses the term was reviewed and approved by the NRC staff.

Constellation does not identify the documents associated with the referenced approvals. It appears that Constellation with the use of was reviewed and approved by the NRC staff is incorporating information including in other licensing requests (e.g., design certification, combined operating license) submitted to the NRC. Section 50.32, Elimination of repetition, of Title 10 of the Code of Federal Regulations (10 CFR) permit the incorporation by information contained in previous applications, statements, or reports filed with the NRC, given the references are clear and specific. Constellations use of was reviewed and approved by the NRC staff is neither clear nor specific.

The NRC staff is reviewing the CIM information against the applicable clauses in (IEEE) Standard 603-1991, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations. This IEEE Standard is incorporated by reference in 10 CFR 50.55a(h) and it establishes the minimum functional design criteria for the power, instrumentation, and control portions of nuclear power generating station safety systems. To evaluate compliance of the CIM with IEEE 603-1991, Clauses 5.3 and 5.4 and conformance with Positions 1, 6, 7, and 8 in Section 2 of NRC DI&C ISG-04:

a. For each occurrence of the term was reviewed and approved by the NRC staff in Tables 3.2.5-1 and 3.2.21-1 please identify the documents related to the approval by title and revision number. In Constellation response, include the date the document was submitted to the NRC, identify the associated licensing actions (e.g., design certification, combined operating license),

b. For each document, please identify the specific parts of the documents that Constellation intends to incorporate by reference, if Constellation is not incorporating the document in its entirety. In the identification of each part, please indicate the applicable clauses in IEEE Std. 603-1991 that the information is intended to demonstrate compliance and indicate whether the information is intended to demonstrate conformance with applicable positions in Section 2 of NRC DI&C ISG-04.

c. For each document, please address differences in terminology usage between the document and the Limerick digital I&C LAR (i.e., proposed plant protection system (PPS)) to ensure clarity.

d. For each document, please identify information that may be superseded by information in the LTR included with the letter dated August 12, 2022 or other parts of the Limerick digital I&C LAR or later revisions of the document.

e. If the documents have not been filed with the NRC, provide the refenced information that demonstrates compliance with applicable IEEE 603-1991 clauses and conformance with applicable positions in DI&C ISG-04.

2. (OI-56 and OI-78) In Section 3.5.14.6 of the LTR attached to the letter dated August 12, 2022, Constellation identifies how the proposed PPS would meet the applicable requirements in Clause 5.12.2 of IEEE 603-1991. In this section, the Licensee refers to the documents used to support the NRC staffs inspection and closure of ITAAC 2.5.02.14 as part of the NRCs affirmative finding under 10 CFR 52.103(g) for Vogtle, Unit 4.

It appears that Constellation with its refence to the ITAAC closure form is incorporating information in documents associated with that ITAAC closure into the Limerick digital I&C LAR. Documents included in other licensing requests (e.g., design certification, combined operating license) submitted to the NRC can be incorporated by reference. Section 50.32, Elimination of repetition, of Title 10 of the Code of Federal Regulations (10 CFR) permit the incorporation by information contained in previous applications, statements, or reports filed with the NRC, given the references are clear and specific. However, it does not appear that the documents associated with the ITAAC closure have been filed with the NRC.

The NRC staff is reviewing the CIM information against the applicable clauses in IEEE 603-1991. This IEEE Standard is incorporated by reference in 10 CFR 50.55a(h) and it establishes the minimum functional design criteria for the power, instrumentation, and control portions of nuclear power generating station safety systems. To evaluate compliance of the CIM with IEEE 603-1991, Clause 5.12.2:

a. For each of the document(s) that the Licensee is incorporating by reference associated with the closure of ITAAC 2.5.02.14, please identify the document(s) by title and revision number. In the response, include the date the document was submitted to (i.e., filed with) the NRC, identify the associated licensing actions (e.g., design certification, combined operating license),

b. For each of the document(s), please identify the specific parts of the documents that Constellation intends to incorporate by reference, if Constellation is not incorporating the document in its entirety. In the identification of each part, please indicate the applicable clause(s) in IEEE Std. 603-1991 that the information is intended to demonstrate compliance.

c. For each of the document(s), please address differences in terminology usage between the document and the Limerick digital I&C LAR (i.e.,

proposed PPS) to ensure clarity.

d. For each of the document(s), please identify information that may be superseded by information in the LTR included with the letter dated August 12, 2022 or other parts of the Limerick digital I&C LAR or.

e. If the document(s) have not been filed with the NRC, provide the refenced information that demonstrates compliance with IEEE 603-1991, Clause 5.12.2.

3. (OI-56 and OI-78) In Constellations letter dated July 31, 2023, the Licensee submitted a copy of APP-GW-GLR-611, Revision 3, AP1000 Design Certification ITAAC 2.5.02.14: Component Interface Module Design Process Technical Report.

Also, in letter dated November 29, 2022, Constellation submitted a copy of WCAP-17179, Revision 6, AP1000 Component Interface Module Technical Report. In the letter dated November 29, 2022, the Licensee identified the parts of WCAP-17179 applicable to the Limerick digital I&C LAR and addressed the terminology differences between the WCAP-17179 and the Limerick digital I&C LAR. It appears parts of the APP-GW-GLR-611 are not applicable to the Limerick digital I&C LAR and no mapping between the differing terminology used in the APP-GW-GLR-611 and the Limerick digital I&C LAR.

The NRC staff is reviewing the CIM information against the applicable clauses in IEEE 603-1991. This IEEE Standard is incorporated by reference in 10 CFR 50.55a(h) and it establishes the minimum functional design criteria for the power, instrumentation, and control portions of nuclear power generating station safety systems. To evaluate compliance of the CIM with IEEE 603-1991, Clauses 5.3 and 5.4:

a. Specify which parts of APP-GW-GLR-611, Revision 3, are applicable to the Limerick digital I&C LAR. In the identification of each part, please indicate the applicable clauses in IEEE Std. 603-1991 that the information is intended to demonstrate compliance and indicate whether the information is intended to demonstrate conformance with Positions 1, 6, 7, and 8 in Section 2 of NRC DI&C ISG-04.

b. Address the differences in terminology usage in APP-GW-GLR-611, Revision 3, and the Limerick digital I&C LAR.

c. Identify information in APP-GW-GLR-611 that may be superseded by information in the LTR included with the letter dated August 12, 2022 or other parts of the Limerick digital I&C LAR.

4. In the letters dated September26, 2022, February8, 2023, March30, 2023, April5, 2023, June26, 2023, and September12, 2023, Constellation included documents concerning human factors engineering (e.g., human factors plan, results summary reports) that contain both export-controlled and proprietary information. In its letters, Constellation requested that information in these documents be withheld from public disclosure per Section 2.390, Public inspections, exemptions, requests for withholding, of 10 CFR. Section 2.390(b)(1)(i)(A) of 10CFR states, in part, the first and successive pages containing information sought to be withheld must be readily visible mark at the top or other suitable marking with language substantially similar to "confidential information submitted under 10 CFR 2.390," "withhold from public disclosure under 10 CFR 2.390,"or "proprietary," to indicate the information contains information to be withheld. The marking of Official Use Only used in the human factors engineering documents do not indicate that the document contains export-control or proprietary information that Constellation is requesting to be withheld. Section 2.390(b)(1)(i)(B) of 10CFR states, in part, that on each page containing information sought to be withheld from public disclosure, the basis for proposing the information be withheld specified adjacent (i.e., portion markings) to the information. The documents lack portion markings indicating the basis for withholding the information from public release. Constellation did not provide portion markings to distinguishing between the export-controlled and proprietary information. The human factors engineering documents lack the markings required by 10CFR 2.390(b)(i). Additionally, proper identification of different types of information is necessary to ensure proper handling and storage of each type of information.

For each of the human factors engineering documents that contain both export-controlled and proprietary information, identify the export-controlled information.

If you have any questions, please contact me.

Best Regards, Michael L. Marshall, Jr.

Senior Project Manager

Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

301-415-2871

Docket No. 50-352 and 50-353