ML24270A261
| ML24270A261 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/17/2024 |
| From: | Edwards T Plant Licensing Branch 1 |
| To: | Constellation Energy Generation |
| Klett, AL | |
| Shared Package | |
| ML24270A266 | List: |
| References | |
| EPID L-2024-LRM-0009 | |
| Download: ML24270A261 (6) | |
Text
October 17, 2024 LICENSEE:
Constellation Energy Generation, LLC FACILITY:
Peach Bottom Atomic Power Station, Units 2 and 3
SUBJECT:
SUMMARY
OF MAY 14, 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 May 14, 2024, a partially closed public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Constellation Energy Generation, LLC (Constellation, the licensee) at NRC headquarters in Rockville, Maryland. 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 (I&C) upgrade to the emergency core cooling system (ECCS) compensated level system at Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom). The meeting notice and agenda, dated April 23, 2024, are available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24131A139. The list of attendees is provided in the enclosure. The presentations used by the NRC staff and representatives of the licensee are available in ADAMS at ML24134A203 and ML24121A186, respectively.
The NRC staff described lessons learned and insights from past pre-application meetings, license amendment reviews, and topical report reviews involving digital systems. The NRC staff described the differences between the tiered and alternate review process discussed in Digital I&C Interim Staff Guidance 06 (ISG-06), Revision 2, Licensing Process, (ML18269A259). The NRC staff described the importance of vendor oversight for LARs prepared using the alternate review process described in ISG-06, Revision 2. Also, the NRC staff described the relationship between a digital upgrade licensing review, vendor inspections, and region-based inspections.
The NRC staff stressed the importance of pre-application meetings and encouraged their use.
The NRC staff agreed to a request from Constellation for more discussions focused on lessons learned involving license amendment reviews and topical report reviews involving field programmable gate arrays (FPGA) during a future pre-application meeting.
The representatives from Constellation described the licensees plan to replace hardware and software of the current ECCS compensated level system. The representatives from Constellation gave a high-level overview of the current ECCS compensated level system and post accident monitoring (PAM) system at Peach Bottom. The licensee described the digital upgrade that it plans to make to those systems. Constellation stated that it plans to use the NRC approved RadICS I&C platform topical report (ML16274A348) for this upgrade. The licensee stated that it plans to request that the NRC staff use the alternate review process described in ISG-06, Revision 2 for the review of the planned LAR.
The representatives from Constellation described its projects scope and licensing approach.
The NRC staff asked if the replacement of the hardware and software would result in changes in the number of sensors, setpoints or calculations. Constellation confirmed that there will be no sensor consolidation, change in setpoints, or changes in calculations in the ECCS compensated level system or PAM system. The NRC staff asked for clarification on the configuration and isolation of the individual units I&C systems. Constellation stated that there are multiple panels in the cable spreading rooms of each unit. Constellation cannot say if each ECCS system had its own panel. Further stating, panels are mostly separated by logic subsystem.
The licensee described how its project is organized, including Curtiss-Wright (CW) and Sargent
& Lundys roles in support of the proposed licensing action. Constellation stated that CWs digital safety system, based upon the RadICS platform, would replace the current Foxboro SPEC 200s in Peach Bottom. Constellation described that CW would design, manufacture, test, install, license and support through their subsidiary ScienTech. The representatives for CW noted that ScienTech does not have an NRC approved quality assurance program description topical report. The representatives for CW stated that it does not plan on submitting a quality assurance (QA) manual to the NRC for review or approval. The representatives for CW described the relationship between RPC Radics LLC and NewClear Day, and the support those organization would provide to CW.
The NRC staff and licensee discussed topics for future presubmittal meetings, which included QA, ISG-06s pre-requisites, secure development and operational environment, commercial grade dedication, regulatory commitments, use of portals during audits (including open items list), and surveillance intervals. The licensee requested that the next presubmittal meeting focus on QA.
No regulatory decisions were made during the meeting. Public meeting feedback forms were not received, but feedback was received via email. The individual that sent the email wanted to make sure that NRC staff was aware that Radiy, HF Controls - FPGA, Nuclear Protection and Control are NRC approved platforms in addition to Advanced Logic System and Highly Integrated Protection System Platform. Additionally, the individual stated that all microprocessor-based platforms use field programmable gate arrays. Also, the individual stated that ISG-04 should be withdrawn by the NRC, because it has been superseded with the issuance Regulatory Guide 1.152, Revision 4, Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants that endorses Institute of Electrical and Electronics Standard (IEEE) 7-4.3.2, IEEE Standard Criteria for Programmable Digital Devices in Safety Systems of Nuclear Power Generating Stations The correspondence can be found in ADAMS at ML24163A352.
If you have any questions, please direct them to Michael Marshall at 301-415-2871 or michael.marshall@nrc.gov or to me at 301-415-1721 or theo.edwards@nrc.gov.
Sincerely,
/RA/
Theo L. Edwards, 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 MAY 14, 2024, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC CONCERNING PEACH BOTTOM UNITS NOS. 2 & 3 Name Organization Bo Pham U.S. Nuclear Regulatory Commission (NRC)
Christina Antonescu NRC David Rahn NRC Deanna Zhang NRC En De Chen NRC Fanta Sacko NRC Hipo Gonzalez NRC Jack Zhao NRC Joseph Ashcraft NRC Louis Dumont NRC Matthew Hamm NRC Michael Marshall NRC Ming Li NRC Samir Darbali NRC Steven Alferink NRC Summer Sun NRC Tania Martinez Navedo NRC Theo Edwards NRC William Roggenbrodt NRC Amy Huber Constellation Energy Generation, LLC (Constellation)
Brian Wright Constellation Christian Ramos Constellation David Helker Constellation Francis Mascitelli Constellation John Hopson Constellation Lindsay Hollingshead Constellation Matthew Rector Constellation Pablo Guardado Constellation Richard Gropp Constellation Richard Gropp Constellation Sailaja Mokkapati Constellation Steve Dragovich Constellation Wade Scott Constellation John Schrage Sargent & Lundy Nathan Rector Sargent & Lundy Pareez Golub Sargent & Lundy Name Organization Ryanna Runyon Sargent & Lundy Sandra Jannetty Sargent & Lundy Adam Boswell Curtiss-Wright Martin Murphy Curtiss-Wright Michael Kosman Curtiss-Wright Robert Ammon Curtiss-Wright Theresa Sutter Curtiss-Wright Alfred W Hyde Dominion Energy Clayton Crouch Dominion Energy Mary H Miller Dominion Energy Richard Stattel General Electric Raymond Herb Southern Company
ML24270A266 (Package)
ML24131A139 (Meeting Notice)
ML24270A261 (Meeting Summary)
NRC-001 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/PM NRR/DORL/LPL1/LAiT NAME TEdwards MMarshall CAdams DATE 9/25/2024 10/2/2024 10/3/2024 OFFICE NRR/DORL/LPL3/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME SLent HGonzález TEdwards DATE 10/4/2024 10/7/2024 10/17/2024