ML24057A427

Response to Requests for Additional Information (RAIs 1, 2, and 3) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control

ML24057A427
Person / Time
Site:	Limerick
Issue date:	02/26/2024
From:	David Helker Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24057A426	List: ML24057A427
References
Download: ML24057A427 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com

ATTACHMENT 3 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390

10 CFR 50.90

February 26, 2024

U.S. Nuclear Regulatory Commissio n 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:

Response to Requests for Additional Information (RAIs 1, 2, and 3) for 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)

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 S ystem (ADAMS) Accession No. ML22269A5690).

2. 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 12, 2023 (ADAMS Accession No. ML23255A095)

3. Email from Michael Marshall, U.S. Nuclear Regulatory Commission to Francis Mascitelli, Constellation Energy Generation, LLC, 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), dated January 26, 2024 (ADAMS Accession No. ML24026A292)

ATTACHMENT 3 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390.

When separated, the cover letter is decontrolled.

Limerick DMP RAIs 1, 2, 3 Response Docket Nos. 50-352 and 50-353 February 26, 2024 Page 2

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).

In Reference 2, CEG submitted a LAR supplement that replaced in its entirety the original license amendment request dated September 26, 2022. CEG replaced the original submittal to address issues associated with proprietary/non-proprietary information.

In Reference 3, the NRC notified CEG that additional information is needed to complete its review of the Reference 2 submittal.

to this letter provides the response to request for additional information for RAIs 1, 2, and 3.

contains the Westinghouse Electric Company (WEC) affidavit supporting the proprietary doc uments contained in Attachment 3.

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 3 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.

contains the WEC proprietary documents referenced in Attachment 1.

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 2 letter. CEG has concluded that the information provided in this RAI response 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 RAI response letter does not affect the bases for concluding t hat neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendments.

This RAI response 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 267-533-5677 or Ashley Rickey at 267-533-1427.

ATTACHMENT 3 TRANSMITTED HEREWITH CONT AINS PROP RIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390.

When separated, the cover letter is decontrolled.

Limerick DMP RAIs 1, 2, 3 Response Docket Nos. 50-352 and 50-353 February 26, 2024 Page 3

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 26 th day of February 2024.

Respectfully,

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

r Attachments: 1. Response to Requests for Additional Information (RAIs 1, 2, and 3) fo 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)

2. WEC Affidavit CAW-24-008 for WEC Documents in Attachment 3

3. WEC proprietary documents referenced in Attachment 1.

cc: USNRC Region I, Regional Administrator w/ attachments USNRC Project Manager, LGS "

USNRC Senior Resident Inspector, LGS "

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

ATTACHMENT 3 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390.

When separated, the cover letter is decontrolled.

Limerick DMP RAIs 1, 2, 3 Response Docket Nos. 50-352 and 50-353 February 26, 2024 Page 4

bcc:

Senior Vice President - MidAtlantic Operations w/o attachments Senior Vice President - Governance & Oversight "

Vice President - Nuclear Security and Licensing "

Site Vice President - LGS "

Plant Manager - LGS "

Director, Operations - LGS "

Director, Site Engineering - LGS "

Director, Site Maintenance - LGS "

Director, Org. Performance and Regulatory "

Director, Licensing - KSA "

Director, Risk Management - KSA "

Director, Engineering - KSA "

Sr. Manager, Site Training - LGS "

PA DEP BRP Inspector - LGS, SSB2-4 "

Manager, Regulatory Assurance - LGS Sr. Manager, Licensing-KSA "

Sr. Manager, Risk Management - KSA "

Commitment Coordinator - KSA "

J. Berg - LGS "

G. J. Bonanni - LGS "

Z. Ballard - LGS "

K. P. Cawley - LGS "

B. T. Devine - LGS "

M. S. Foote - Cantera "

J. R. George Jr. - LGS "

P. E. Golub - KSA "

S. R. Hesse - LGS "

A. Holtz - KSA "

P. Krueger - LGS "

K. L. Marriner - LGS "

D. L. Molteni - LGS "

A. Rickey - KSA "

M. Samselski - LGS "

J. L. Schrage - KSA "

S. Schumacher - LGS "

G. P. Segner - LGS "

P. J. Tarpinian Jr. - KSA "

w/ attachments

Licensing Records - KSA "

F. J. Mascitelli - KSA "

D. L. Molteni - LGS "

M. Samselski - LGS "

ATTACHMENT 3 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390.

When separated, the cover letter is decontrolled.

Attachment 1

License Amendment Request Supplement

Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353

Response to Requests for Additional Information (RAIs 1, 2, and 3) for 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)

Attachment 1 Page 1 of 12

By letter dated September 26, 2022 (Agencywide Documents Access and Management System Accession No. ML22269A569; non-public), as supplemented by letters dated August 12, 2022 (ML22224A149), November 29, 2022 (ML22333A817), February 8, 2023 (ML23039A141), February 15, 2023 (ML23046A266), March 30, 2023 (ML23089A324), April 5, 2023 (ML23095A223), June 26, 2023 (ML23177A224), July 31, 2023 (ML23212B236),

September 12, 2023 (ML23255A095), October 30, 2023 (ML23303A223), and November 21, 2023 (ML23325A206), Constellation Energy Generation, LLC (CEG) submitted a 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).

The supplement dated September 12, 2023 replaces in its entirety the original license amendment request dated Septembe r 26, 2022. 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 September 12, 2023, the content of the replacement and the original are the same.

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 CEG on January 19 and 26, 2024, and it was agreed that a response would be provided within 30 days of the date of the NRC's January 26, 2024 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.

Below is the Constellation Energy Generation (CEG) response to address NRC staff RAIs 1, 2, and 3.

RAI 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 t he 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.

Attachment 1 Page 2 of 12

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 st ation 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 in corporating the document in its entirety. In the identification of each part, please indi cate the applicable clauses in IEEE Std. 603-1991 that the information is intend ed to demonstrate compliance and indicate whether the information is intende d to demonstrate conformance with applicable pos itions 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 t he letter dated August 12, 2022 or ot her parts of the Limerick digital I&C LAR or later revisions of the docum ent.

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

CEG Response:

1.a The relevant clauses cited in the RAI (i.e., IEEE Std 603, Clauses 5.3 and 5.4, and DI&C-ISG-04 Section 2, positions 1, 6, 7, 8) in which the disposition refers to NRC review and approval, pertain to the criteria for both the quality of the design process and equipment qualification.

As will be shown in the below response and the other responses within this RAI, previous NRC review of the CIM equipment qualification is not credited for the Limerick Digital Modernization Project (DMP). The CIM equipment qualification is included in the Limerick DMP qualification program. To address quality of the design process, and in particular the quality of the software design process, NUREG 0800, Chapter 7, Branch Technical Position (BTP) 7-14 provides NRC review guidance for assessing the quality of the software design process. Therefore, the Attachment 1 Page 3 of 12

response below and other responses will be based on the documentation that is expected to be provided to an NRC reviewer to assess the adequacy of the software design process using BTP 7-14.

The Licensing Technical Report incorrectly used the term was reviewed and approved by the NRC staff. The intent of this statement was to credit the NRC staffs review of the CIM development process during the AP1000 ITAAC 2.5.02.14 process. As such, the sentence should have said:

was reviewed by the NRC staff against the ITAAC 2.5.02.14 acceptance criteria and no issues were identified.

The following table provides a list of CIM documentation that fulfills the NUREG-0800, Branch Technical Position 7-14, Sections B.2.1, B.2.2, and B.2.3 criteria.

BTP 7-14 Guidance On Software Reviews for Digital Computer-Based Instrumentation And Control Systems BTP 7-14, Section B.2.1, Software Life Westinghouse Document Cycle Process Planning Software Management Plan (SMP) 6105-00000, CIM-SRNC Management Plan, Rev. 13 Software Development Plan (SDP) 6105-00014, CIM-SRNC FPGA Development Plan, Rev. 6 Software Quality Assurance Plan (SQAP) 6105-00001, CIM-SRNC QA Plan, Rev. 11 Attachment 1 Page 4 of 12 Software Integration Plan (SIntP) WAAP-128791, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0, Section 6 Software Installation Plan (SInstP) WAAP-128791, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0, Section 7 Software Maintenance Plan (SMaintP) WAAP-128791, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0, Section 8 Software Training Plan (STrngP) WAAP-128791, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0, Section 9 Software Operations Plan (SOP) WAAP-128791, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0, Section 10 Software Safety Plan (SSP) WAAP-128791, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0, Section 11 Software Verification and Validation Plan 6105-00013, CIM-SRNC IV&V Plan, Rev. 14 (SVVP)

Software Configuration Management Plan 6105-00002, CIM-SRNC CM Plan, Rev. 12 (SCMP)

Software Test Plan (STP) 6105-00005, CIM-SRNC Test Plan, Rev. 11 BTP 7-14, Section B.2.2 Software Life Westinghouse Document Cycle Process Implementation Safety analyses 6105-60019, CIM-SRNC Software Hazard Analysis Report, Rev. 4 Verification and validation analysis and 6105-00092, CIM-SRNC IVV Phase Summary test reports Report, Rev. 11 Configuration management reports 6105-00053, CIM-SRNC Configuration Status, Rev. 22 Testing Activities WNA-TR-02718-GEN, CIM SRNC Subsystem Test Report, Rev. 4 BTP 7-14, B.2.3, Software Life Cycle Westinghouse Document Process Design Outputs Software requirements specifications 6105-10004, SRNC FPGA Software (SRS) Requirements Specification, Rev. 13 6105-20004, CIM FPGA Software Requirements Specification, Rev. 17 Hardware and software architecture Included as part of software design descriptions descriptions (SAD)

Software design specifications (SDS) 6105-10014, SRNC FPGA Software Design Description, Rev. 5 6105-20014, CIM FPGA Software Design Description, Rev. 5 Attachment 1 Page 5 of 12

Code listings CIM FPGA, Release 1.155 SRNC FPGA, Release 1.95 Under software configuration control within Westinghouse - Available for audit Build documents 6105-10025, SRNC FPGA Build Procedure, Rev. 4 6105-20025, CIM FPGA Build Procedure, Rev.

4 Installation configuration tables N/A - No configuration of the CIM in the field.

Operations manuals Included as part of the system technical manual.

Maintenance manuals Included as part of the system technical manual.

Training manuals Included as part of the system training.

Notes:

1.WAAP-12789 was created specific for the Limerick DMP and provides an extract from 6105-00015, CIM-SRNC Software Program Manual that fulfill BTP 7-14 criteria.

The documents listed in above table (except for those identified as available for Audit), have been provided in Attachment 3 of this RAI response.

1.b IEEE Std. 603-1991, Section 5.3 and Positions 1, 6, 7, and 8 in Section 2 of NRC DI&C ISG-04 are related to the quality of the development process. Therefore, all of the CIM documents listed in 1.a, which fulfills the BTP 7-14 criteria, are used to demonstrate compliance to the criteria listed above, and therefore applicable to the Limerick DMP, with exceptions noted below. IEEE Std. 603-1991, Section 5.4 has to do with equipment qualification. The discussion in these documents on the AP1000 equipment qualification for the CIM is not applicable for the Limerick DMP since the CIM was included as part of the Limerick DMP equipment qualification program. The documents listed in the BTP 7-14 table above are applicable to the Limerick DMP with the following exceptions.

6105-00000, CIM-SRNC Management Plan, Rev. 13:

• 6105-00004, CIM-SRNC EQ Plan and 6105-00064, CIM-SRNC Equipment Qualification Summary Report do not apply since the CIM was included as part of the Limerick equipment qualification testing. See Section 4 of WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project for a discussion on Limerick equipment qualification.

• 6105-00012, CIM/SRNC vs. DAS Diversity is not applicable for Limerick. The CIM diversity characteristics are explained in WNA-Attachment 1 Page 6 of 12

• AR-01074-GLIM-P, Defense in Depth and Diversity Common Cause Failure Coping Analysis.

6105-00014, CIM-SRNC FPGA Development Plan, Rev. 6:

• 6105-00012, CIM/SRNC vs. DAS Diversity is not applicable for Limerick. The CIM diversity characteristics are explained in WNA-AR-01074-GLIM-P, Defense in Depth and Diversity Common Cause Failure Coping Analysis.

6105-00001, CIM-SRNC QA Plan, Rev. 11:

• 6105-00004, CIM-SRNC EQ Plan does not apply since the CIM was included as part of the Limerick equipment qualification testing.

See Section 4 of WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project for a discussion on Limerick equipment qualification.

WAAP-12879, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0:

• The entire document is applicable to Limerick.

6105-00013, CIM-SRNC IV&V Plan, Rev. 14:

• The entire document is applicable to Limerick.

6105-00002, CIM-SRNC CM Plan, Rev. 12:

• 6105-00012, CIM/SRNC vs. DAS Diversity is not applicable for Limerick. The CIM diversity characteristics are explained in WNA-AR-01074-GLIM-P, Defense in Depth and Diversity Common Cause Failure Coping Analysis.

6105-00005, CIM-SRNC Test Plan, Rev. 11:

• 6105-00004, CIM-SRNC EQ Plan does not apply since the CIM was included as part of the Limerick equipment qualification testing.

See Section 4 of WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project for a discussion on Limerick equipment qualification.

• 6105-00012, CIM/SRNC vs. DAS Diversity is not applicable for Limerick. The CIM diversity characteristics are explained in WNA-AR-01074-GLIM-P, Defense in Depth and Diversity Common Cause Failure Coping Analysis.

6105-60019, CIM-SRNC Software Hazard Analysis Report, Rev. 4:

• The entire document is applicable to Limerick.

6105-00092, CIM-SRNC IVV Phase Summary Report, Rev. 11:

• 6105-00012, CIM/SRNC vs. DAS Diversity is not applicable for Limerick. The CIM diversity characteristics are explained in WNA-AR-01074-GLIM-P, Defense in Depth and Diversity Common Cause Failure Coping Analysis. The following other diversity documents are also not applicable:

Attachment 1 Page 7 of 12

o IC-12-041, Position Paper Westinghouse Electric Company Diversity between AP1000 Protection & Safety Monitoring System (PMS) and Diverse Actuation System (DAS).

o IC-12-042, CIM-SRNC and DAS Human Diversity Evaluation.

6105-00053, CIM-SRNC Configuration Status, Rev. 22

• The CIM-SRNC equipment qualification documentation do not apply since the CIM was included as part of the Limerick equipment qualification testing:

o 6105-00004, CIM-SRNC EQ Plan o 6105-00064, CIM-SRNC Equipment Qualification Summary Report o 6105-50000, CIM-SRNC EMC Test Procedure o 6105-50001, CIM-SRNC Seismic Test Procedure o 6105-50002, CIM-SRNC Environmental Test Procedure o 6105-50003, CIM-SRNC Monitoring Procedure o 6105-50004, CIM-SRNC EMC Lab Report From Wyle o 6105-50005, CIM-SRNC EMC Lab Report From Keystone o 6105-50006, CIM-SRNC Seismic Lab Report From Westinghouse o 6105-50007, CIM-SRNC EMC Qualification Report o 6105-50008, CIM-SRNC Seismic Qualification Report o 6105-50009, CIM-SRNC Environmental Qualification Report

• 6105-00012, CIM/SRNC vs. DAS Diversity is not applicable for Limerick. The CIM diversity characteristics are explained in WNA-AR-01074-GLIM-P, Defense in Depth and Diversity Common Cause Failure Coping Analysis.

WNA-TR-02718-GEN, CIM SRNC Subsystem Test Report, Rev. 4:

• The entire document is applicable to Limerick.

6105-10004, SRNC FPGA Software Requirements Specification, Rev. 13:

• The entire document is applicable to Limerick.

6105-20004, CIM FPGA Software Requirements Specification, Rev. 17:

• The entire document is applicable to Limerick.

6105-10014, SRNC FPGA Software Design Description, Rev. 5

• The entire document is applicable to Limerick.

6105-20014, CIM FPGA Software Design Description, Rev. 5

• The entire document is applicable to Limerick.

6105-10025, SRNC FPGA Build Procedure, Rev. 4

• The entire document is applicable to Limerick.

6105-20025, CIM FPGA Build Procedure, Rev. 4

• The entire document is applicable to Limerick.

1.c

The following provides clarification on the terminology differences for each document listed in 1.a. 6105-00000, CIM-SRNC Management Attachment 1 Page 8 of 12

Plan, Rev. 13:

• Protection and Safety Monitoring System (PMS) is now Plant Protection System (PPS). Plant Control System (PLS) is now Distributed Control System (DCS). The diverse actuation system (DAS) is now the Diverse Protection System (DPS).

6105-00014, CIM-SRNC FPGA Development Plan, Rev. 6:

• No terminology differences.

6105-00001, CIM-SRNC QA Plan, Rev. 11:

• No terminology differences.

WAAP-12879, Extract of CIM-SRNC Software Program Manual Applicable to the Limerick DMP, Rev. 0:

• No terminology differences.

6105-00013, CIM-SRNC IV&V Plan, Rev. 14:

• No terminology differences.

6105-00002, CIM-SRNC CM Plan, Rev. 12:

• No terminology differences.

6105-00005, CIM-SRNC Test Plan, Rev. 11:

• No terminology differences.

6105-60019, CIM-SRNC Software Hazard Analysis Report, Rev. 4:

• The Safety System is the PPS. The Control System is the DCS.

The Computer independent control system is the DPS.

6105-00092, CIM-SRNC IVV Phase Summary Report, Rev. 11:

• The PMS is the PPS. The PLS is the DCS. The DAS is the DPS.

6105-00053, CIM-SRNC Configuration Status, Rev. 22

• No terminology differences.

WNA-TR-02718-GEN, CIM SRNC Subsystem Test Report, Rev. 4:

• No terminology differences.

6105-10004, SRNC FPGA Software Requirements Specification, Rev. 13:

• No terminology differences.

6105-20004, CIM FPGA Software Requirements Specification, Rev. 17:

• The Safety System is the PPS. The Non-safety System is the DCS. The Computer independent control system is the DPS.

6105-10014, SRNC FPGA Software Design Description, Rev. 5

• The Safety System is the PPS. The Non-safety System is the DCS.

6105-20014, CIM FPGA Software Design Description, Rev. 5

• The Safety System is the PPS. The Non-safety System is the DCS. The Computer independent control system is the DPS.

Attachment 1 Page 9 of 12

6105-10025, SRNC FPGA Build Procedure, Rev. 4

• No terminology differences.

6105-20025, CIM FPGA Build Procedure, Rev. 4

• No terminology differences.

1.d

As discussed in the response to 1.b., some of the documents discuss the AP1000 equipment qualification program for the CIM. This is not applicable for Limerick and is superseded by the equipment qualification description in Section 4 of WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project. The CIM DAS diversity discussion is also not applicable for Limerick and is superseded by the CIM diversity characteristics explained in WNA-AR-01074-GLIM-P, Defense in Depth and Diversity Common Cause Failure Coping Analysis.

1.e

The documents listed in 1.a. have been provided in Attachment 3 of this RAI response letter.

RAI 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 reference 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 st ation 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 Attachment 1 Page 10 of 12

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 referenced 12.2. information that demonstrates compliance with IEEE 603-1991, Clause 5.

CEG Response:

2.a

The relevant clause cited in the RAI (i.e., IEEE Std 603, Clauses 5.12.2) in which the disposition refers to developed and reviewed by the NRC, pertain to the criteria for the quality of the design process for embedded diagnostics in the safety system. Similar to the response to the first RAI, the CIM documents that an NRC staff reviewer would evaluate to ascertain the adequacy of the design process of the diagnostic functions are based on the documents cited in BTP 7-14.

Basically, the same documents appl y because the CIM diagnostics are integrated completely within the CIM software development process.

See response to 1.a. for a listing of the ITAAC 2.5.02.14 documents that fulfill the applicable BTP 7-14 criteria.

2.b

See response to 1.b. for what is applicable to Limerick digital I&C LAR.

2.c

See response to 1.c. for terminology differences.

2.d

See response to 1.d. for where information is superseded.

Attachment 1 Page 11 of 12

2.e

The documents listed in 1.a. are provided in Attachment 3 of this RAI response letter.

RAI 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 st ation 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.

CEG Response:

3.a

As described above in the response to 1.a., the relevant clauses cited in the RAI (i.e., IEEE Std 603, Clauses 5.3 and 5.4, and DI&C-ISG-04 Section 2, positions 1, 6, 7, 8) pertain to the criteria for both the quality of the design process and equipment qualification. APP-GW-GLR-611 provides a detailed list of documents generated as part of the CIM development life cycle. Not all of these documents are needed to satisfy BTP 7-14 review criteria but are all applicable to the Limerick DMP, with the exception of:

• APP-GW-G1-002, AP1000 Equipment Qualification Methodology Attachment 1 Page 12 of 12

does not apply to the Limerick DMP since the CIM was included as part of the Limerick equipment qualification testing. See Section 4 of WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project for a discussion on Limerick equipment qualification.

3.b

The following provides clarification on the terminology differences for APP-GW-GLR-611:

• The PMS is the PPS. The PLS is the DCS. The DAS is the DPS.

3.c

As discussed in the response to 3.a., APP-GW-GLR-611 discusses the AP1000 equipment qualification program for the CIM. This is not applicable for Limerick and is superseded by the equipment qualification description in Section 4 of WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project.

Attachment 2

License Amendment Request Supplement

Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353

WEC Affidavit CAW-24-008 for WEC Documents in Attachment 3

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-008 Page 1 of 3

Commonwealth of Pennsylvania:

County of Butler:

(1) I, Zachary Harper, Senior Manager, Licensing, 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 6105-00000, Revision 13, 6 105-00014, Revision 6, 6105-00001, Revision 11, WAAP-12879, Revision 0, 6105-00013, Revi sion 14, 6105-00002, Revision 12, 6105-00005, Revision 11, 6105-60019, Revision 4, 6105-00092, Revision 11, 6105-00053, Revision 22, WNA-TR-02718-GEN, Revision 4, 6105-10004, Revision 13, 6105-20004, Revision 17, 6105-10014, Revision 5, 6105-20014, Revision 5, 6105-10025, Revision 4, 6105-20025, Revision 4 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 fr om 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 docum ent 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

• • • This record was final approved on 02/21/2024 15:47:38. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-008 Page 2 of 3

others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

(5) Westinghouse has policies in place to identify pr oprietary 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.

• • • This record was final approved on 02/21/2024 15:47:38. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-008 Page 3 of 3

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 pe nalty of perjury that the foregoing is true and correct.

Executed on: 2/21/2024 _____________________________

Signed electronically by Zachary Harper

• • • This record was final approved on 02/21/2024 15:47:38. (This statement was added by the PRIME system upon its validation)

CAW-24-008 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 Feb-21-2024 15:47:38

Files approved on Feb-21-2024

• • • This record was final approved on 02/21/2024 15:47:38. (This statement was added by the PRIME system upon its validation)

Attachment 3

License Amendment Request Supplement

Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353

WEC proprietary documents referenced in Attachment 1

6105-00000_Revision_13 6105-00001_Revision_11 6105-00002_Revision_12 6105-00005_Revision_11 6105-00013_Revision_14 6105-00014_Revision_06 6105-00053_Revision_22 6105-00092_Revision_11 6105-10004_Revision_13 6105-10014_Revision_05 6105-10025_Revision_04 6105-20004_Revision_17 6105-20014_Revision_05 6105-20025_Revision_04 6105-60019_Revision_04 WAAP-12879_Revision_0 WNA-TR-02718-GEN_Revision_4