ML24325A553
| ML24325A553 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/21/2024 |
| From: | Robert Davis Plant Licensing Branch 1 |
| To: | Constellation Energy Generation |
| Klett, AL | |
| References | |
| EPID L-2024-LRM-0009 | |
| Download: ML24325A553 (1) | |
Text
November 21, 2024 LICENSEE:
Constellation Energy Generation, LLC FACILITY:
Peach Bottom Atomic Power Station, Units 2 and 3
SUBJECT:
SUMMARY
OF OCTOBER 29, 2024, PUBLIC OBSERVATION MEETING WITH CONSTELLATION ENERGY GENERATION, LLC REGARDING 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 October 29, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff held a public observation meeting with Constellation Energy Generation, LLC (Constellation, licensee) at NRC Headquarters in Rockville, Maryland. The purpose of the meeting was for Constellation and the NRC to discuss a proposed license amendment request (LAR) regarding a digital instrumentation and controls (DI&C) upgrade to the emergency core cooling system (ECCS) compensated level system for Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom). The meeting notice and agenda, dated October 18, 2024, are available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24292A180. The enclosure to this summary contains a list of attendees. The licensee prepared adjusted presentation slides which are available in ADAMS at ML24305A095 (original slides can be found at ML24302A242). The NRC staff presented an additional set of slides which are available in ADAMS at ML24305A096.
During a previous public meeting on July 22, 2024 (ML24206A178), the NRC staff described information needed, including select information from DI&C interim staff guidance (ISG)
DI&C-ISG-06, Licensing Process, Enclosure B, to support the NRC staffs review of the proposed ECCS DI&C upgrade for Peach Bottom. During the October 29, 2024, public meeting, Constellation representatives asked for a breakdown of the regulatory requirements associated with the information the NRC staff identified during the July 22, 2024, meeting. The NRC staff described the differences between the DI&C-ISG-06 Tiered Review Process and the Alternate Review Process (ARP) for Constellations proposed LAR. The NRC staff explained that a Tier 1 review is best suited for LARs that reference an NRC-approved topical report without changes or deviations, a Tier 2 review is best suited for LARs that reference an NRC-approved topical report with deviations such as revised software development process or different hardware, and a Tier 3 review is best suited for a LAR that does not reference an NRC-approved topical report or if the system is being developed by a vendor that does not have an NRC-approved quality assurance (QA) program. The staff also explained that the ARP is a streamlined version of a Tier 1 review where the staff relies on previous NRC approvals, plans for system and software development, and the licensees plan for vendor oversight. The NRC staff described the breakdown of how the documents listed in Enclosure B of the DI&C-ISG-06 are related to requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 50. The NRC staff also indicated the necessary documents to perform the review of the LAR against applicable criteria in Appendix B of 10 CFR Part 50.
Constellation representatives asked what type of information should be included in item 1.14, System Response Time Analysis Report, from Enclosure B of DI&C-ISG-06. The NRC staff responded that it should be a document summarizing, through analytical methods, the data from a system response time analysis. The licensee asked for clarification on item 1.11, Software Requirements Specification, from Enclosure B of DI&C-ISG-06; specifically, whether this is a document describing the process or output of the software requirements specifications. The NRC staff clarified that the information identified in item 1.11 of Enclosure B is specific to the outputs from the software requirements process, which includes the released version of the software requirements specification and associated independent verification and validation (IV&V) outputs.
The licensee indicated that a future roadmap describing the documents that will be submitted to the NRC with the initial application and the documents that will be submitted as a supplement will be helpful to ensure they meet the regulatory requirements. The NRC staff recommended that when submitting the proposed LAR to the NRC for review, the licensee includes in its submittal a list of anticipated supplemental documents, the information presented in each document, and planned submittal date. The NRC staff stated that there is a need to understand any deviations from the referenced instrumentation and controls platform topical report, the roles and responsibilities of the organizations involved in the modification, the processes and procedures used to perform the system and software development and IV&V activities for the modification, and a description of how these processes and procedures fit into the QA program of the organization performing these activities.
The NRC staff did not make any regulatory decisions at the meeting. Members of the public were in attendance. Public Meeting Feedback forms were not received. The NRC received one comment congratulating the staff on the helpfulness of dialogue throughout the meeting.
Please direct any inquiries to me at (301) 415-0805, or email Rachael.Davis@nrc.gov.
/RA/
Rachael Davis, Project Manager Licensing Data Analytics, Tools, and Assessments Branch 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 OCTOBER 29, 2024, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 Name Organization Aaron Armstrong U.S Nuclear Regulatory Commission (NRC)
Audrey Klett NRC Deanna Zhang NRC Eric Benner NRC Fanta Sacko NRC Jack Zhao NRC Jason English NRC Kerri Kavanagh NRC Michael Marshall NRC Ming Li NRC Neal Sheehan NRC Rachael Davis NRC Samir Darbali NRC Summer Sun NRC William Roggenbrodt NRC Lisa Brown Constellation Energy Generation, LLC (Constellation)
Pablo Guardado Constellation Steve Dragovich Constellation Stephen Flickinger Constellation Wagas Abdullah Constellation John Schrage Sargent Lundy Pareez Golub Sargent Lundy Rylee Runyon Sargent Lundy Marty Murphy Curtiss-Wright Michael Kosman Curtiss-Wright Robert Ammon Curtiss-Wright Alan Campbell Member of the public - Nuclear Energy Institution Clayton Crouch Member of the public - Dominion Energy Mary Miller Member of the Public - Dominion Energy
Package: ML24305A107 Meeting Notice: ML24292A180 Meeting Summary: ML24325A553 Meeting Slides: ML24302A242 (Constellation slides 1)
Meeting Slides: ML24305A095 (Constellation slides 2)
Meeting Slides: ML24305A096 (NRC Slides)
OFFICE NRR/DORL/LDATA/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NAME RDavis KEntz HGonzalez DATE 11/20/2024 11/21/2024 11/21/2024