ML24124A043
| ML24124A043 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/03/2024 |
| From: | David Helker Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML24124A042 | List: |
| References | |
| EPID L-2022-LLA-0140 | |
| Download: ML24124A043 (1) | |
Text
200 Exelon Way Kennett Square, PA 19348 www.ConstellationEnergy.com ATTACHMENTS 1 and 5 TRANSMITTED HEREWITH CONTAIN PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390.
When separated from Attachments 1 and 5, this cover letter is decontrolled.
ATTACHMENTS 1 and 5 TRANSMITTED HEREWITH CONTAIN PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 May 3, 2024 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:
Response to Requests for Additional Information (RAIs 9 through 14) 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 System (ADAMS) Accession No. ML22269A569).
- 2. Constellation Energy Generation, LLC (CEG) letter to the U.S. Nuclear Regulatory Commission (NRC), "Resubmittal of 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) - To Address Proprietary Issues with INL HFE Reports," 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 March 19, 2024 (ADAMS Accession No. ML24079A292)
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).
Constellation
Limerick DMP LAR RAIs 9 through 14 Response Docket Nos. 50-352 and 50-353 May 3, 2024 Page 2 ATTACHMENTS 1 AND 5 TRANSMITTED HEREWITH CONTAIN PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 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 contains the proprietary Westinghouse Electric Company (WEC)
LIM-24-066-P, Revision 1, Limerick NRC Equipment Qualification Request for Additional Information, (Response to RAIs 9 through 13).
to this letter contains the non-proprietary WEC LIM-24-066-NP, Revision 1, Limerick NRC Equipment Qualification Request for Additional Information, (Response to RAIs 9 through 13).
to this letter contains the WEC proprietary affidavit, CAW-24-022, Revision 0, for Attachment 1.
to this letter contains the non-proprietary CEG response to the request for additional information for RAI 14.
contains the proprietary CEG NE-381 Specification, Nuclear Safety Related Specification for Fiber-Optic Instrumentation & Control System Cable, supporting the CEG response in Attachment 4 request for additional information for RAI 14.
contains the CEG proprietary affidavit for Attachment 5.
contains the 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 Attachments should reference this request letter.
contains the affidavit signed by CEG, 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. CEG requests that the CEG proprietary information contained in Attachment 5 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 CEG proprietary information or the CEG affidavit provided in the applicable Attachments should reference this request letter.
Limerick DMP LAR RAIs 9 through 14 Response Docket Nos. 50-352 and 50-353 May 3, 2024 Page 3 ATTACHMENTS 1 AND 5 TRANSMITTED HEREWITH CONTAIN PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 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 that 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 Francis.Mascitelli@constellation.com.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 3rd day of May 2024.
Respectfully, David P. Helker Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments: 1. WEC LIM-24-066-P, Revision 1, Limerick NRC Equipment Qualification Request for Additional Information, (Response to RAIs 9 through 13) -
Proprietary
- 2. WEC LIM-24-066-NP, Revision 1, Limerick NRC Equipment Qualification Request for Additional Information, (Response to RAIs 9 through 13) -
Non-proprietary
- 5. CEG NE-381 Specification, Nuclear Safety Related Specification for
Limerick DMP LAR RAIs 9 through 14 Response Docket Nos. 50-352 and 50-353 May 3, 2024 Page 4 Fiber-Optic Instrumentation & Control System Cable - Proprietary
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 1, 5 Department of Environmental Protection
License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 WEC LIM-24-066-P, Revision 1, Limerick NRC Equipment Qualification Request for Additional Information, (Response to RAIs 9 through 13) - Proprietary
License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 WEC LIM-24-066-NP, Revision 1, Limerick NRC Equipment Qualification Request for Additional Information, (Response to RAIs 9 through 13) - Non-proprietary
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
©2024 Westinghouse Electric Company LLC. All Rights Reserved Electronically Approved Records Are Authenticated in the Electronic Document Management System Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Mr. Jerry Segner Principal Project Manager Constellation Energy Generation, LLC Limerick Generating Station 3146 Sanatoga Road Pottstown, PA 19464 jerry.segner@constellation.com Direct Telephone:
(412) 699-1250 E-mail:
parastoo.muse@westinghouse.com Contract:
00800304 Sales Order:
156102 Our Ref:
LIM-24-066-NP, Rev. 1 April 23, 2024 CONSTELLATION ENERGY GENERATION LIMERICK UNITS 1 AND 2 DIGITAL MODERNIZATION PROJECT Limerick NRC Equipment Qualification Request for Additional Information Attachments:
- 1. Isolation Barrier Testing Status
- 2. EQ Open Issues
- 3. Circuits Requiring Additional Testing or Evaluation
Dear Mr. Segner:
The following provides Westinghouses responses to NRC RAIs 9 thru 14.
- 9. (OI 60) For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, Section 50.55a(h), Protection and safety systems, of Title 10 of the Code of Federal Regulations (10 CFR), requires, in part, that protection systems meet the requirements in Institute of Electrical and Electronic Engineers (IEEE) Std 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations. Limerick received construction permits on May 19, 1974, therefore its protection system has to meet the requirements in IEEE Std 279-1971. Clause 4.4 of IEEE Std 279-1971, Equipment Qualification, states that type test data or reasonable engineering extrapolation based on test data shall be available to verify that protection system equipment will be capable of meeting, on a continuing basis, the performance requirements determined to be necessary for achieving the system requirements.
Westinghouse Non-Proprietary Class 3
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 2 of 27 Our Ref: LIM-24-066-NP General Design Criterion (GDC) 22, Protection System Independence, in Appendix A to 10 CFR Part 50 requires that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in loss of the protection function. GDC 24, Separation of Protection and Control Systems requires that the protection system shall be separated from control systems to the extent that failure of any single control system component or channel, or failure or removal from service of any single protection system component or channel which is common to the control and protection systems leaves intact a system satisfying all reliability, redundancy, and independence requirements of the protection system.
Interconnection of the protection and control systems shall be limited so as to assure that safety is not significantly impaired.
To meet the above regulatory requirements, the Class 1E to non-Class 1E isolation qualification testing should ensure any failure of non-Class 1E devices interfacing with Class 1E equipment will not impair the safety function of the Class 1E equipment. In Section 4.0 of Attachment 1 to its letter dated September 12, 2023, the licensee stated that Regulatory Guide (RG) 1.209, Guidelines for environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants and RG 1.75, Physical Independence of Electric Systems are applicable to the to the license amendment request. The licensee does not clearly indicate which portions, if any, of the guidance in these guides are used in its equipment qualification efforts.
In Section 4 of the Licensing Technical Report included with Constellations letter dated September 12, 2023, the licensee states, in part, that the Class 1E isolation circuits will be tested to the Limerick fault requirements to show compliance to IEEE Std. 384.
However, the proposed license amendment request, including the Qualification Summary Report for the Plant Protection System Upgrade for Limerick Units 1 and 2 (Qualification Summary Report) included with the licensees letter dated January 26, 2024 does not include summary description of the Class 1E to non-Class 1E isolation testing result for the plant protection system (PPS).
Please provide summary description of the qualification testing of the Class 1E to non-Class 1E isolation barriers used for the Limerick PPS.
WEC Response:
Westinghouse is completing a qualification program for the Class 1E to non-Class 1E isolation barriers, including test and analysis of isolation barriers for fault (IEEE 384-1992 section 7.2.2), seismic, environmental and EMC requirements. Specific to fault testing, Westinghouse performs type tests on the isolation barriers' ability to withstand the maximum credible transverse and common mode fault in accordance with Limerick site conditions. The tests consider both alternating current (AC) and direct current (DC) faults, positive and negative polarity. The tests also verify the barriers ability to withstand short circuits, open circuits and grounded circuits on the faulted side of the barrier.
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 3 of 27 Our Ref: LIM-24-066-NP RG 1.75 section B and C provide the linkage to IEEE 384-1992. The Westinghouse fault program (WNA-TP-07626-GEN) considers the positions in RG 1.75 Section C paragraphs 1-5 as applicable.
RG 1.209 has been incorporated into the seismic, environmental, and EMC qualification programs - both RG 1.209 and IEEE 323 are cited in EQ-MR-13-GLIM Limerick Units 1 and 2 Equipment Qualification Strategy and Plan for the Plant Protection System Upgrade. The plan considers the positions in RG 1.209 paragraphs 1-5 as applicable.
The following detailed information has been summarized from WNA-TP-07626-GEN Rev.
0, which is the fault test procedure applied to the Limerick PPS isolation barriers.
Fault testing of isolation barriers consists of the following tests:
[
]a,c Non-1E barriers are required to be faulted on the Non-1E side only while monitoring the 1E side. Barriers that isolate between diverse 1E systems are required to protect against faults in both directions, so fault testing is required on both sides of the barrier.
Fault levels used for the testing are as follows:
[
]a,c
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 4 of 27 Our Ref: LIM-24-066-NP Acceptance criteria are as follows:
The isolation barrier shall not allow the safety functions interfacing with the barrier component to be degraded below an acceptable level. This shall be demonstrated by ensuring that the barrier components do not allow electrical perturbations on the chart recorder [
]a,c In addition, the isolation barrier shall not catch fire or sustain an arc that could cause the dispersion of conductive material.
If conductive material is dispersed during the test, while not resulting in a perturbation that could degrade the safety function below an acceptable level, an evaluation shall be performed to demonstrate that the dispersion would not result in a credible degradation beyond an acceptable level of the safety function.
Test Status:
A summary table of the isolation barriers tested for Limerick is presented in Attachment 1.
The status for each isolation barrier for fault, seismic, environmental, and EMC testing is provided. In summary, Westinghouse has tested 30 isolation barrier configurations for the Limerick project. The activities remaining are the fault test data analysis, the fault test report, and the IEEE 384 compliance (fault test) summary report. The remaining activities will be completed per the project schedule, and the data will be dispositioned against the acceptance criteria above.
- 10. (OIs 61, 64, and 76) For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, Section 50.55a(h) of 10 CFR, requires, in part, that protection systems meet the requirements in IEEE Std 279-1971. Limerick received construction permits on May 19, 1974, therefore its protection system has to meet the requirements in IEEE Std 279-1971. Clause 4.4 of IEEE Std 279-1971 states that type test data or reasonable engineering extrapolation based on test data shall be available to verify that protection system equipment will be capable of meeting, on a continuing basis, the performance requirements determined to be necessary for achieving the system requirements.
In Table 2.3-3 of Qualification Summary Report, the licensee lists some critical hardware components in the PPS test specimen cabinets. In Section 2.2.3 of the Qualification Summary Report, the licensee states, to simulate the production PPS equipment, the equipment qualification (EQ) test specimen layout and functionality were designed to represent the functions of the full system. It appears that the summary results for all the components included in the PPS test specimen cabinets EQ-1 and EQ-2 are not included in the Qualification Summary Report.
a) It appears that other critical hardware components in the PPS test specimen cabinets EQ-1 and EQ-2, which are shown on Figure 2.3-2 of Qualification Summary Report are not included in Table 2.3-3, such as component interface
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 5 of 27 Our Ref: LIM-24-066-NP module and its associated components, high amperage relay panel, and associated circuit parts, such as Ovation analog input modules, sequence of events modules, and remote interface modules.
Please provide the part numbers and product revisions for the components listed above that were included as part of the PPS test specimen cabinets EQ-1 and EQ-2 qualified for the Limerick digital modernization project.
WEC Response:
Part Description Westinghouse Part Number Product Revision Remote Node Interface 2A10429G25 Backplane 5X00454G01 Rev 06 Fiber Modules 5X00453G02 Rev 05 HSL Termination Unit 2C48054G01 7
OZDV 114B Fiber Optic Modems 2A10425H05 0000 CIM HARP 10173D40G07 4
Double-Width Transition Panel 2C48498G05 16 RNI to DWTP Adapter 2C48498G08 17 Safety Remote Node Controller Base 2C48498G04 6
Safety Remote Node Controller 2C48498G03 7
Component Interface Module 2C48498G01 11 Component Interface Base 2C48498G02 6
24V DC/DC Converter Power Supply 2A10759G03 3
I/O Base 2A10429G01 14 Single-Width Transition Panel 2C48034G01 5
Analog Input, Emod, 1-5 Vdc 2A10429G30 32 Analog Input, Emod, 0-1 mA 2A10429G32 32 Analog Input, Pmod, 0-1 mA 2A10429G33 15 Analog Input, Pmod, 1-5 VDC 2A10429G31 9
Dataforth Isolator 2A10424G10 A
Dataforth Isolator 2A10424G01 C
Dataforth Isolator 2A10424G07 A
Dataforth Isolator 2A10424G08 A
Dataforth Isolator 2A10424G09 A
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 6 of 27 Our Ref: LIM-24-066-NP Part Description Westinghouse Part Number Product Revision Dataforth, E/I 0-100m Vrms / 4-20mA Module 2A10424G15 A
Fiber Optic Modem 90193G02 E
QUINT-PS/1AC/24V/20/WH Gen-3 Power Supply 2A10655G01 5
QUINT-PS/1AC/24DC/10/WH Gen-3 Power Supply 2A10655G02 1
[
]a,c 2A10851G02 5
[
]a,c 2A10851G03 8
HSL Power Supply Panel 2C48529G02 8
Sola DC/DC Converter 2A10693G01 3
AO650 Termination Unit 2C48058G01 5
DI621 Termination Unit 2C48061G05 16 RPS SCRAM TU 10178D05G01 0
HSL Termination Unit 10173D21G10 3
Dual-Width Transition Panel 2A10429G20 18 Analog Input, Emod, 4-20mA 2A10429G23 32 Analog Input, Pmod, 4-20mA 2A10429G24 9
Compact Enhanced SOE, Single Ended 2A10429G15 11 Dataforth Isolator 2A10424G04 A
Dataforth Isolator 2A10424G05 A
b) The ((
)), which is not part of the approved generic Common Q platform, is included in the proposed Limerick PPS and cabinet testing. A summary description of qualification testing results is not in the license amendment request, including the Qualification Summary Report.
Please provide summary description of qualification results for the ((
)).
WEC Response:
[
]a,c Westinghouse 2A10851G02, was tested satisfactorily in the following programs for the Limerick PPS upgrade project. As tested, the power supply was included as a subcomponent in the Power Distribution Panel Assembly, 10173D15G01, which was part of the Limerick PPS components and cabinet 10173D40G02 EQ testing, and 10173D15G02, which was part of the Limerick PPS cabinet 10173D40G01 EQ testing. 10173D15G01,
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 7 of 27 Our Ref: LIM-24-066-NP 10173D40G01, and 10173D40G02 are found in the summary report, EQ-QR-433-GLIM, which was submitted to the NRC on January 26th, 2024, as well as the following reports.
Seismic Environmental EMC JID 23-00364 EQLR-529 EQLR-555 EQLR-536 EQLR-544 EQLR-522 Westinghouse has received a newer vendor product revision of [
]a,c (i.e., Revision 10) that was not included in the tests above. This new revision is being evaluated as a part of the EQ Reconciliation process, including re-analysis or re-test as applicable for the seismic, environmental, and EMC requirements, in order to qualify the new revision for use in the Limerick PPS.
Activities to address the new revision of 2A10851 that is not qualified are included in the program schedule.
c) The Sola DC/AC converter, which is not part of the approved generic Common Q platform, is included in the cabinet testing. A summary description of the qualification testing results in not in the license amendment request, including the Qualification Summary Report. It is not clear from the license amendment request if the Sola DC/AC converter is part of the proposed Limerick PPS.
Please clarify if the Sola DC/AC converter is part used in the PPS. If yes, please provide its summary description of qualification results.
WEC Response:
Note: the item is the Sola DC/DC converter, not DC/AC.
Sola SCD 30S5-DN, Westinghouse 2A10693G01 / PS01465H01, was tested satisfactorily in the following programs for the Limerick PPS upgrade project. As tested, the converter was included in the Standard Safety HSL Power Supply Panel Assembly, 2C48529G02, which was part of the Limerick PPS cabinet 10173D40G0 EQ testing. 10173D40G02 is found in the summary report, EQ-QR-433-GLIM, which was submitted to the NRC on January 26th, 2024 as well as the following reports.
Seismic Environmental EMC JID 23-00364 EQLR-555 EQLR-544
- 11. For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, Section 50.55a(h) of 10 CFR, requires, in part, that protection systems meet the requirements in IEEE Std 279-1971. Limerick received construction permits on May 19, 1974, therefore its protection system has to meet the requirements in IEEE Std 279-1971. Clause 4.4 of IEEE Std 279-1971, states that type test data or reasonable engineering extrapolation based on test data shall be available to verify that protection system equipment will be capable of meeting, on a continuing basis, the
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 8 of 27 Our Ref: LIM-24-066-NP performance requirements determined to be necessary for achieving the system requirements.
a) In Section 4.4.2 of Qualification Summary Report the license stated evaluation identified 51 differences in the production hardware (in comparison to the EQ test specimens) that require further evaluation and the licensee stated An evaluation/analysis shall be performed by equipment qualification engineers to determine if any of the identified hardware is qualified by previous testing and/or analysis; otherwise, additional testing shall be performed to qualify the remaining components. Additionally, the licensee states that the summary report shall be revised to include all additional analysis and/or testing required to demonstrate the qualification of all remaining hardware. It appears that the qualification testing for all the components in the Limerick PPS has not been completed.
- i.
Please list and describe the 51 differences that needed further evaluation. Also, describe the resolution of the 51 differences that were not addressed.
ii.
ii. Please list, including part numbers and version, the remaining hardware that additional analysis or test is needed to demonstrate qualification of the hardware.
WEC Response:
Westinghouse completed a comparison of the as-tested EQ design to the as-designed production PPS equipment. 51 differences were referred to seismic, environmental, and EMC for further evaluation.
Documents EQ-EV-410-GLIM Rev 0 Seismic and Environmental Reconciliation of the Plant Protection System for Limerick Units 1 & 2 and EQ-EV-411-GLIM Rev 0 Electromagnetic Compatibility Reconciliation of the Limerick Plant Protection System Test Configuration to the Production Configuration were issued to evaluate the 51 differences. A summary of the status of each of the 51 differences is in the table below. Details are provided in Attachment 2, including a difference-by-difference summary of the dispositions or planned test with applicable part numbers for each of seismic, environmental, and EMC.
Seismic Environmental EMC Total Differences Considered 51 51 51 Dispositioned in EQ-EV-410-GLIM by analysis 21 34 Dispositioned in EQ-EV-411-GLIM by analysis 14 Issues Remaining Open for reconciliation testing 30 17 37 b) In Section 3.3.2 of the Qualification Summary Report, the licensee states that several cables for the PPS specimen test cabinet EQ-1 and EQ-2 are not
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 9 of 27 Our Ref: LIM-24-066-NP qualified under either the combination wave surge test or the ring wave surge test and must be reassessed for their electromagnetic compatibility (EMC) performance.
Please provide summary results to that demonstrate the qualification of the PPS cabinet cables which were not qualified by (i.e., included in) the test program described in the Qualification Summary Report.
WEC Response:
Cables that are classified as cables under test in the EMC test program are associated with circuits that represent identical or similar circuits in the production system. Cables under test are those cables that leave their enclosure and can comingle with other cables.
The EMC test program documented in EQLR-544 identified seven circuits where the test results required additional evaluation or testing, as shown in Attachment
- 3.
With the exception of the circuit associated with cable EQ2 S36, continuous observation of the display showing the monitoring software results confirmed that the signals associated with the Fluke signal generator (support equipment) were the only signals generating the unacceptable results for the AI687 and AI688 cards. The results suggested that the applied disturbance was affecting the Fluke signal generator output, resulting in the observed anomalies. The immunity of the AI687 and AI688 cards could not be justified based on the test results and efforts to modify the test configuration to isolate the support equipment from the applied disturbances were unsuccessful. Therefore, the circuits associated with cables EQ1 S23, EQ1 S24, EQ1 S27, EQ1 S28, EQ2 S39, and EQ2 S42 were identified as requiring additional EMC evaluation or testing.
The circuit associated with Cable EQ2 S36 suffered a blown fuse when subjected to the IEC 61000-4-5 combination wave surge test. Replacement of the as-designed fuse with a higher rated fuse allowed completion of the combination wave surge testing through the 2 kV test level, but with unacceptable results on the AI687 card. Similar to the results on the other circuits where unacceptable results were observed, the performance degradation appeared to be associated with the support equipment. The immunity of the AI687 card could not be justified based on the test results and efforts to modify the test configuration to isolate the support equipment from the applied disturbances were unsuccessful. Therefore, the circuit associated with cable EQ2 S36 was identified as requiring additional EMC evaluation or testing.
Supplemental EMC testing will be performed to address circuits that are not qualified/exhibited unresolved anomalies. The remaining activities will be completed per the project schedule, and the data will be dispositioned against the applicable acceptance criteria.
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 10 of 27 Our Ref: LIM-24-066-NP c) In Section 3.3.2.2 of Qualification Summary Report, the licensee states There were sixty-eight anomalies identified during the EMC testing. As shown in Table 3.3-5, upon conclusion of the EMC testing, most of the anomalies had been resolved. However, the licensee indicated that some of the anomalies have not been resolved. An anomaly may show some non-compliance with relevant qualification criteria and needs to be addressed to demonstrate the equipment qualification.
Please list and describe the unresolved anomalies. Also, describe how those anomalies have been resolved.
WEC Response:
The unresolved anomalies are identified and described in the response to RAI 11b.
Supplemental EMC testing will be performed to address circuits that are not qualified/exhibited unresolved anomalies. The remaining activities will be completed per the project schedule, and the data will be dispositioned against the applicable acceptance criteria.
- 12. For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, Section 50.55a(h)10 CFR requires, in part, that protection systems meet the requirements in IEEE Std 279-1971. Limerick received construction permits on May 19, 1974, therefore its protection system has to meet the requirements in IEEE Std 279-1971. Clause 4.4 of IEEE Std 279-1971 states that type test data or reasonable engineering extrapolation based on test data shall be available to verify that protection system equipment will be capable of meeting, on a continuing basis, the performance requirements determined to be necessary for achieving the system requirements.
((
]
In Section 4.0 of Attachment 1 to its letter dated September 12, 2023, the licensee stated that RG 1.180, Guidelines for Evaluating Electromatic and Radio-Frequency Interferences in Safety-Related Instrumentation and Control Systems, is applicable to the license amendment request. Section 2.2.3 Qualification Summary Report the licensee stated that the PPS shall meet RG 1.180, Revision 2. In Section 3.3.1, the licensee stated that EMC testing was performed in accordance with both the Electric Power Research Institute (EPRI) Topical Report TR-102323 and RG 1.80. The regulatory guidance in RG 1.180, Rev. 2 states that regardless of which susceptibility testing program is chosen, either set of test methods (i.e., MIL-STD-461G or IEC 610000-4) should be applied in its entirety, without selective application of individual methods (i.e., no mixing and matching of test methods). It appears from the discussion
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 11 of 27 Our Ref: LIM-24-066-NP in the Qualification Summary Report that there was selective application of the individual methods.
Please provide justification to support or clarification regarding the deviation from the guidance in RG 1.180 regarding the mixed use of IEC 61000-4-3 and MIL-STD-416G, RS103 tests. Also, describe any other deviations from guidance in RG 1.180.
WEC Response:
The purpose of the IEC 61000-4-3 testing is to verify the ability of the equipment to withstand radiated electric fields. Table 7 of U.S. NRC Regulatory Guide 1.180-R2 identifies that electric field radiated susceptibility performed in accordance with the commercial test methods should be performed in accordance with test method IEC 61000-4-3 over the frequency range of 26 MHz to 6 GHz. If wireless communication devices operating above 6 GHz are expected to be used at the site of installation, then electric field radiated susceptibility testing is indicated up to 10 GHz.
Westinghouse follows the commercial standards for susceptibility testing and performs electric field radiated susceptibility testing in accordance with test method IEC 61000-4-3 over the frequency range of 26 MHz to 6 GHz, as indicated in Table 7 and Table 19 of U.S. NRC Regulatory Guide 1.180-R2. Testing in accordance with IEC 61000-4-3 from 26 MHz to 6 GHz fulfills the requirement to test electric field susceptibility testing in accordance with the commercial standard test suite. Supplemental electric field radiated susceptibility testing with test method MIL-STD-461G, RS103 over the frequency range of 6 GHz to 10 GHz was then performed to address any wireless communications devices operating above 6 GHz since test standard IEC 61000-4-3 only defines the test method up to 6 GHz.
This approach parallels the methodology used for qualification of AP1000 systems, performed to the requirements of U.S. NRC Regularly Guide 1.180, Revision 1, which defines IEC 61000-4-3 testing up to 1 GHz and overall electric field radiated susceptibility testing up to 10 GHz. Electric field radiated susceptibility testing to address U.S. NRC Regularly Guide 1.180, Revision 1 was performed in accordance with MIL-STD-461, RS103 from 1 GHz to 10 GHz to supplement the IEC 61000-4-3 testing performed from 26 MHz to 1 GHz.
The RS103 test calls for square wave modulation with a 50% duty cycle, while the IEC 61000-4-3 test calls for sinusoidal wave modulation with an 80% duty cycle. MIL-STD-461G identifies that pulse modulation at a 1 kHz rate, 50% duty cycle, (alternately termed 1 kHz square wave modulation) is specified for several reasons. One kHz is within the bandpass of most analog circuits such as audio or video. The fast rise and fall times of the pulse causes the signal to have significant harmonic content high in frequency and can be detrimental to digital circuits. Response of electronics has been associated with energy present and a square wave results in high average power. The modulation encompasses many signal modulations encountered in actual use. The square wave is a severe form of amplitude modulation used in communications.
NUREG/CR-6782 provides a comparison of U.S. military and commercial (IEC) guidance and concluded that there are differences in the high-frequency test methodologies, but these differences are probably not substantial enough to make a significant difference in the test results. At frequencies of above 1 GHz, NUREG/CR-
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 12 of 27 Our Ref: LIM-24-066-NP 6782 suggests that the MIL-STD-461, RS103 test be performed when there is a concern about high-frequency transmitters being activated in an area with safety-related I&C equipment noting that the study was performed when 1 GHz was the maximum frequency for testing performed in accordance with IEC 61000-4-3.
- 13. For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, Section 50.55a(h) of 10 CFR requires that protection systems meet the requirements in IEEE Std 279-1971 Limerick received construction permits on May 19, 1974, therefore its protection system has to meet the requirements in IEEE Std 279-1971 In Section 4.0 of Attachment 1 of its letter dated September 12, 2023, the licensee stated that RG 1.209 is applicable to the license amendment request. The licensee does not clearly indicate which portions, if any, of the guidance in this guide is used in its equipment qualification efforts. Section 5 of EPRI TR-107330 which is endorsed in RG 1.209 includes guidance on acceptance and operability testing. In Section 2.3.3 of EQ Summary Report, the licensee states that procedures also included baseline functional tests to check the performance of the EQ PPS system before and after the EQ tests were performed. The actual conditions achieved during pre-test and post-test were not included in Table 3.2-2.
Please provide the actual conditions achieved or a justification for the absence of the pre-test and post-test for the component environmental testing.
WEC Response:
EPRI TR-107330 Section 5 indicates that pre-test baseline testing be performed prior to environmental testing. Pre-test and post-test baseline functional testing was performed before and after the PPS component level environmental test.
Section 3.2 of the EQ Summary Report, which was submitted to the NRC on January 26th, 2024, summarizes the environmental testing performed for the PPS at Limerick; however, Pre-test and post-test results were not summarized in Table 3.2-2 for the PPS component testing. The results for these two conditions have been summarized in the following table.
(Note: Table notes 1 and 2 correspond to the same table notes found in Table 3.2-2 of the EQ Summary Report.)
Cycle Required Voltage
[Tolerance]
(Actual Voltage)
Required Hz
[Tolerance]
(Actual Hz)
Start Time /
End Time Required Temp.
[Tolerance]
(Actual Temp.)
Required %RH
[Tolerance]
(Actual %RH)
Required Hrs (Actual Hrs)(1)
Pre-Test Ambient 120 Vac / 125 Vdc [+/-2v]
(120.2 - 120.6 Vac)
(124.6 - 126.1 Vdc) 60 Hz [+/-1]
(60.0 Hz) 15:01 6/5/23(2) 08:21 6/6/23(2) 75°F [+/-10]
(74.6°F - 75.3°F) 50%RH [+/-10]
(41.0 - 59.1%RH)
~2 Hrs (17.3 Hrs)
Post-Test Ambient 120 Vac / 125 Vdc [+/-2]
(119.8 - 120.2 Vac)
(124.3 - 126.6 Vdc) 60 Hz [+/-1]
(60.0 Hz) 11:16 6/13/23 14:03 6/13/23 75°F [+/-10]
(65.1°F - 75.0°F) 50%RH [+/-10]
(47.7 - 52.7%RH)
~2 Hrs (2.8 Hrs)
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 13 of 27 Our Ref: LIM-24-066-NP Pre-test and post-test baseline functional testing was performed while the EUT was operated at the nominal input conditions listed in the above table. Acceptable functional results were reported. After completing the pre-test baseline functional test, the EUT was left to saturate at the normal ambient conditions while being continuously monitored.
After this, the environmental test profile was performed. After completing the environmental test profile, the EUT was returned to normal ambient conditions and left to saturate while being continuously monitored. Following this duration, the post-test baseline functional test was performed. Acceptable functional results were reported.
- 14. (OI 55) For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, Section 50.55a(h) of 10 CFR requires that protection systems meet the requirements in IEEE Std 279-1971. Limerick received construction permits on May 19, 1974, therefore its protection system has to meet the requirements in IEEE Std 279-1971. Clause 4.4 of IEEE Std 279-1971 states that type test data or reasonable engineering extrapolation based on test data shall be available to verify that protection system equipment will be capable of meeting, on a continuing basis, the performance requirements determined to be necessary for achieving the system requirements.
The NRC staffs evaluation of the Common Q platform topical report identified plant-specific action items (PSAIs) related to communication that must be addressed by an applicant when requesting NRC approval for installation of a safety-related system based on the Common Q platform topical report. In the approved topical report, PSAI 20 states licensee implementing an application based upon the Common Q platform that utilizes fiber optic cables to connect high speed links [HSL] between safety divisions shall ensure that all plant-specific environmental qualification requirements for this cabling are met.
((
))
In Section 6.2.2.19 of the LTR, Constellation explained how the PSAIs would be addressed. For PSAI 20, Constellation stated that it is developing a new fiber optic cable specification specific for the Limerick digital modernization project. Its document number and title are NE-381, Nuclear Safety Related Specification for Fiber-Optic Instrumentation and Control System Cable. This document will ensure the fiber optic cable used for the HSLs meet the LGS site environmental qualification requirements.
In the license amendment request, including the Qualification Summary Report, the licensee has not provided information to demonstrate that the fiber optic cable to connect HSLs between safety divisions meets the Limerick site environmental qualification requirements.
- This record was final approved on 04/24/2024 10:15:48. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 Page 14 of 27 Our Ref: LIM-24-066-NP Provide a summary description of the analysis or testing (including results) that demonstrates all plant-specific environmental qualification requirements for fiber optic cabling connecting the HSLs are met.
CEG to respond.
If you have any questions or require additional information regarding this transmittal, please feel free to contact me at (412) 699-1250.
Sincerely, WESTINGHOUSE ELECTRIC COMPANY LLC Electronically Approved Parastoo Muse Program Manager Attachment (if applicable)
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Westinghouse Non-Proprietary Class 3 - Isolation Barrier Testing Status a,c Page 15 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - Isolation Barrier Testing Status a,c Page 16 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - Isolation Barrier Testing Status a,c Page 17 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - Isolation Barrier Testing Status a,c Page 18 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - Isolation Barrier Testing Status a,c Page 19 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - EQ Open Issues a,c Page 20 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - EQ Open Issues a,c Page 21 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - EQ Open Issues a,c Page 22 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - EQ Open Issues a,c Page 23 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - EQ Open Issues a,c Page 24 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Non-Proprietary Class 3 - EQ Open Issues a,c Page 25 of 27 Our Ref: LIM-24-066-NP
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Westinghouse Proprietary Class 2 - Circuits Requiring Additional Testing or Evaluation a,c Page 26 of 27 Our Ref: LIM-24-066-NP
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©2024 Westinghouse Electric Company LLC. All Rights Reserved Electronically Approved Records Are Authenticated in the Electronic Document Management System Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA cc: Constellation Energy Steven Hesse steven.hesse@constellation.com Kayla Marriner kaylalover.marriner@constellation.com Zina Gavin zina.gavin@constellation.com Mark Samselski mark.samselski@constellation.com David Molteni david.molteni@constellation.com Ashley Rickey Ashley.Rickey@constellation.com Frank Mascitelli Francis.Mascitelli@constellation.com Westinghouse Electric Company LLC Courtney Frank Parastoo Muse Boyan Setchenski Andrew Lutz Steve Merkiel Andrew Barth Cynthia Olesky Warren Odess-Gillett Matt Shakun
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LIM-24-066-NP Revision 1 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 Muse Parastoo Apr-24-2024 10:15:48 Files approved on Apr-24-2024
License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 WEC Proprietary Affidavit, CAW-24-022, Revision 0, for Attachment 1
- This record was final approved on 04/24/2024 13:38:18. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-022 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 the proprietary portions of LIM-24-066-P, 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.
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Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-022 Page 2 of 3 (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 documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
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Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-022 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 penalty of perjury that the foregoing is true and correct.
Executed on: 4/24/2024 Signed electronically by Zachary Harper
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CAW-24-022 Revision 0 Non-Proprietary Class 3
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Approval Information Manager Approval Harper Zachary S Apr-24-2024 13:38:18 Files approved on Apr-24-2024
Attachment 4 License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 CEG Response to Request for Additional Information RAI 14 - Non-Proprietary
, CEG Response to Request for Additional Information RAI 14 Page 1 of 2 (Non-Proprietary)
NRC RAI 14 (OI 55) For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, Section 50.55a(h) of 10 CFR requires that protection systems meet the requirements in IEEE Std 279-1971. Limerick received construction permits on May 19, 1974, therefore its protection system has to meet the requirements in IEEE Std 279-1971. Clause 4.4 of IEEE Std 279-1971 states that type test data or reasonable engineering extrapolation based on test data shall be available to verify that protection system equipment will be capable of meeting, on a continuing basis, the performance requirements determined to be necessary for achieving the system requirements.
The NRC staffs evaluation of the Common Q platform topical report identified plant-specific action items (PSAIs) related to communication that must be addressed by an applicant when requesting NRC approval for installation of a safety-related system based on the Common Q platform topical report. In the approved topical report, PSAI 20 states licensee implementing an application based upon the Common Q platform that utilizes fiber optic cables to connect high speed links [HSL] between safety divisions shall ensure that all plant-specific environmental qualification requirements for this cabling are met.
((
))
In Section 6.2.2.19 of the LTR, Constellation explained how the PSAIs would be addressed. For PSAI 20, Constellation stated that it is developing a new fiber optic cable specification specific for the Limerick digital modernization project. Its document number and title are NE-381, Nuclear Safety Related Specification for Fiber-Optic Instrumentation and Control System Cable. This document will ensure the fiber optic cable used for the HSLs meet the LGS site environmental qualification requirements.
In the license amendment request, including the Qualification Summary Report, the licensee has not provided information to demonstrate that the fiber optic cable to connect HSLs between safety divisions meets the Limerick site environmental qualification requirements.
Provide a summary description of the analysis or testing (including results) that demonstrates all plant-specific environmental qualification requirements for fiber optic cabling connecting the HSLs are met.
CEG Response to RAI 14 For PSAI 20, Specification NE-381, Nuclear Safety Related Specification for Fiber-Optic Instrumentation & Control System Cable provides the technical requirements for the design, fabrication, and delivery of safety related fiber for miscellaneous instrumentation applications at Limerick Generating Station to demonstrate that the fiber optic cable meets the Limerick site environmental qualification requirements. CEG proprietary Specification NE-381 is provided in of this RAI Response submittal.
The Class 1E fiber-optic cable specified shall be suitable for the broadband transmission of high-speed data in a nuclear power plant. The Class 1E fiber-optic cable shall be flame
, CEG Response to Request for Additional Information RAI 14 Page 2 of 2 (Non-Proprietary)
retardant and shall also be resistant to heat, moisture, and nuclear radiation as required by the application. The cable shall be an all-dielectric construction and be suitable for installation in severe electromagnetic environments. The cable thermal and radiation properties shall be such as to maintain its critical optical and physical qualities during normal and abnormal operating conditions.
NE-381 requires a supplier to provide test results that demonstrates the provided Class 1E fiber-optic cable must be able to withstand aging of the cable without any significant change in physical and optical properties over the expected 40-year life of the component in accordance with IEEE 383-1974, Type Test of Class 1E Electric Cables, Field Splices and Connections for Nuclear Power Generating Station.
The specification also requires the ability to operate in thermal and radiation exposure specific for environment service conditions for Limerick Generating Station Units 1&2. The cable must be demonstrated to be qualified to the environments through which it runs.
The cable has not been procured at this time; therefore, test results are not available. The manufacturer test results will be available after the selection of a suitable cable type.
License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 CEG NE-381 Specification, Nuclear Safety Related Specification for Fiber-Optic Instrumentation & Control System Cable - Proprietary
License Amendment Request Supplement Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 CEG Proprietary Affidavit for Attachment 5
AFFIDAVIT for NE-381 Specification, Nuclear Safety Related Specification for Fiber-Optic Instrumentation & Control System Cable Page 1 of 2 Constellation Energy Generation, LLC AFFIDAVIT Commonwealth of Pennsylvania:
County of Chester:
(1) I, Sailaja Mokkapati, Director-Licensing, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Constellation Energy Company, LLC (CEG).
(2) I am requesting CEG NE-381 Specification, Revision 0, Nuclear Safety Related Specification for Fiber-Optic Instrumentation & Control System Cable, be withheld from public disclosure under 10 CFR 2.390.
(3) I have personal knowledge of the criteria and procedures utilized by CEG 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 CEG 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 CEG knowledge, is not available in public sources.
(iii) CEG 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 CEG 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.
(5) CEG 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 CEGs competitors without license from CEG 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).
AFFIDAVIT for NE-381 Specification, Nuclear Safety Related Specification for Fiber-Optic Instrumentation & Control System Cable Page 2 of 2 (c) Its use by a competitor would reduce their expenditure of resources or improve their 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 CEG, its customers or suppliers.
(e) It reveals aspects of past, present, or future CEG or customer funded development plans and programs of potential commercial value to CEG.
(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), (b), and (c) of this Affidavit. Accordingly, a redacted version would be of no value to the public.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 1st day of May 2024.
Signed electronically by: ________________________
Mokkapati, Sailaja Digitally signed by Mokkapati, Sailaja Date: 2024.05.01 14:22:53 -04'00'