ML24206A178
| ML24206A178 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/29/2024 |
| From: | Marshall M Plant Licensing Branch 1 |
| To: | Rhoades D Constellation Energy Generation |
| Klett, AL | |
| References | |
| EPID L-2024-LRM-0009 | |
| Download: ML24206A178 (1) | |
Text
July 29, 2024 LICENSEE:
Constellation Energy Generation, LLC FACILITY:
Peach Bottom Atomic Power Station, Units 2 and 3
SUBJECT:
SUMMARY
OF JULY 22, 2024, PUBLIC MEETING WITH CONSTELLATION ENERGY GENERATION, LLC CONCERNING PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DIGITAL UPGRADE OF THE EMERGENCY CORE COOLING SYSTEM COMPENSATED LEVEL SYSTEM (EPID L-2024-LRM-0009)
On July 22, 2024, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Constellation Energy Generation, LLC (Constellation, the licensee) using video conference software. The purpose of this meeting was for Constellation and the NRC staff to discuss a planned license amendment request (LAR) for a digital instrumentation and controls (DI&C) upgrade to the emergency core cooling system at Peach Bottom Atomic Power Station, Units 2 and 3. The discussion was limited to the quality assurance (QA) aspects of the planned LAR. The meeting notice and agenda, dated July 8, 2024, are available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24190A027. The licensees presentation is available in ADAMS at Accession No. ML24200A231. A list of attendees is provided in the enclosure.
The Constellation representatives stated that they wanted to reach alignment with the NRC staff on the prerequisites for the alternate review process (ARP) licensing review described in DI&C Interim Staff Guidance (ISG) DI&C-ISG-06, Revision 2, Licensing Process, December 2018 (ML18269A259). The context of the discussion was limited to QA and performance of detailed software design implementation. The licensee sought clarification on whether Constellation could use a supplier other than the vendor of an approved topical report discussed in bullet 2.b of section C.2.2 of DI&C-ISG-06 and whether approved in the same bullet meant approval by a licensee.
In response to the licensees questions and comments, the NRC staff stated that use of a supplier other than the vendor of the approved topical report for the digital I&C platform to develop the safety-related application software does not preclude the use of the ARP by the NRC staff. However, the supplier should have an NRC approved Appendix B QA program (i.e.,
an NRC approved quality assurance program description (QAPD) topical report) for the NRC staff to conduct a review using the ARP.
In response to the licensees questions and comments, the NRC staff stated that approved in bullet 2.b of section C.2.2 meant NRC approvalnot approval by a licensee. The NRC staff explained that the ARP relies on previous NRC approvals to improve the efficiency of the NRC staffs review. Regardless of whether the licensee is using the vendor of the approved topical report or another supplier use of the ARP to conduct a review presumes the vendor or supplier has an NRC approved Appendix B QA program (i.e., an approved QAPD topical report).
Using enclosure B of DI&C-ISG-06, Revision 2, the NRC staff identified the information that Constellation would need to include in its planned LAR, if its supplier did not have an NRC -
approved QA program. Specifically, the following items from enclosure B for Tier 1 and Tier 3 would need to be included in the planned LAR:
1.3 Approved Topical Report Safety Evaluation 1.4
System Description
1.5 System Architecture 1.6 (Summary of) Hardware Equipment Qualification 1.7 (Unified Compliance/Conformance Matrix for) IEEE [Institute of Electrical and Electronics Engineers] Stds 603-1991 and 7-4.3.2-2003 1.8 (Changes to) Technical Specifications 1.9 Setpoint Methodology and Calculations 1.10 Secure Development and Operational Environment 1.11 Software Requirements Specification 1.12 Software Design Specification 1.13 Design Analysis Reports for Platform Changes 1.14 System Response Time Analysis Report 1.16 Commercial-Grade Dedication Plan 1.17 Quality Assurance Plan for Hardware, 1.18 (Summary of) Hardware Development Process 2.2 As-Manufactured, System Configuration Documentation 2.3 Summary Test Reports 2.6 System-Level Failure Modes and Effects Analysis 2.9 (Summary of) Electromagnetic Interface, Temperature, Humidity, and Seismic Testing Results 2.10 Commercial-Grade Dedication Report(s)
The NRC staff also described actions that Constellation or its supplier would need to take in order to support a review of the planned LAR by the NRC staff using the ARP described in DI&C-ISG-06, Revision 2. The licensees supplier could submit a QAPD topical report to the NRC for review and approval. If approved by the NRC staff, the licensees supplier could either:
(1) perform commercial grade dedication of the RadICS platform and develop the safety-related application software using the dedicated platform. This allows Constellation to submit the LAR with the content expected of a request being reviewed by the NRC staff in accordance with the ARP described in DI&C-ISG-06, Revision 2. Use of the guidance in Regulatory Guide 1.250, Dedication of Commercial-Grade Digital Instrumentation and Control Items for Use in Nuclear Power Plants, Revision 0, October 2022 (ML22153A408), would provide a means for the licensees supplier to use the International Electrotechnical Commission (IEC) 61508, Functional Safety of Electrical/Electronic/Programmable Electronic Safety-Related Systems, Edition 2.0, safety integrity level certification of the vendor of the instrumentation and controls (I&C) platform topical report components in lieu of performing a commercial grade survey to satisfy the dependability critical characteristic; or (2) rely on the I&C platform topical reports vendors Appendix B compliant QA program for the manufacturing of the I&C platform components, and the licensee or its supplier performs onsite triennial audits of the vendor of the I&C platform under their QA programs.
In addition to the clarifications about bullet 2.b of section C.2.2 of DI&C-ISG-06, the Constellation representatives asked if supplements could be used if the licensee wanted the NRC staff to use the ARP for the planned LAR. The NRC staff informed the licensee that the ARP did not include the use of supplements to address incompleteness in the planned LAR.
One of the other options (i.e., tier) described in DI&C-ISG-06 assumes the use of a supplement.
The NRC staff informed Constellation that the completeness (or lack thereof) would be factored into the estimated review schedule duration.
No regulatory decisions were made during the meeting. No public meeting feedback forms were received.
Please direct any inquiries to Michael Marshall at 301-415-2871 or michael.marshall@nrc.gov.
Sincerely,
/RA/
Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES JULY 22, 2024, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC CONCERNING PEACH BOTTOM ATOMIC POWER, UNITS 2 AND 3 Name Organization Aaron Armstrong U.S. Nuclear Regulatory Commission (NRC)
Samir Darbali NRC Corey Dukehart NRC Kerri Kavanagh NRC Audrey Klett NRC Michael Marshall NRC Ed Miller NRC William Roggenbrodt NRC Fanta Sacko NRC Deanna Zhang NRC Steve Bowers Constellation Energy Generation, LLC (Constellation)
Steve Dragovich Constellation Pablo Guardado Constellation Wendi Para Constellation Zachariah Shukur Constellation Pareez Golub Sargent Lundy Ryanna Runyon Sargent Lundy John Schrage Sargent Lundy Adam Boswell Curtiss-Wright Jana Bergman Curtiss-Wright Dan Hunt Curtiss-Wright Michael Kosman Curtiss-Wright Clayton Crouch Dominion Energy Brian Braithwaite
ML24206A178 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME MMarshall KEntz (PBlechman for)
HGonzález MMarshall DATE 07/24/2024 07/25/2024 07/25/2024 07/29/2024