ML24338A092

Summary of November 8, 2024, Public Observation Meeting with Constellation Energy Generation, LLC on LAR to Support Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System

ML24338A092
Person / Time
Site:	Limerick
Issue date:	12/06/2024
From:	Marshall M Plant Licensing Branch 1
To:
Klett, AL
Shared Package
ML24338A096	List: ML24338A092
References
EPID L-2022-LLA-0140
Download: ML24338A092 (1)

Text

December 6, 2024 LICENSEE:

Constellation Energy Generation, LLC FACILITY:

Limerick Generating Station, Units 1 and 2

SUMMARY

OF NOVEMBER 8, 2024, PUBLIC OBSERVATION MEETING WITH CONSTELLATION ENERGY GENERATION, LLC ON LICENSE AMENDMENT REQUEST TO SUPPORT REPLACEMENT OF EXISTING SAFETY-RELATED ANALOG CONTROL SYSTEMS WITH A SINGLE DIGITAL PLANT PROTECTION SYSTEM (EPID L-2022-LLA-0140)

On November 8, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff held a virtual partially closed observation meeting with Constellation Energy Generation, LLC (the licensee, Constellation). The purpose of the meeting was to discuss a Constellation proposed license condition concerning equipment qualification (EQ) that the licensee plans to submit as part of the digital instrumentation and controls license amendment request for Limerick Generating Station, Units 1 and 2 (Limerick). The meeting notice and agenda, dated October 30, 2024, are available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24312A366. The enclosure to this summary contains a list of attendees. The licensees presentation slides are available in ADAMS at ML24310A260.

During the meeting, the licensee described the structure and content of its proposed EQ license condition to require completion of EQ testing of specific list of components included in the proposed license condition by reference. The referenced document would also describe the testing that would be performed. The licensee intends the proposed license condition to be a substitute for EQ summary test results of equipment that have not been tested, yet. The NRC staff shared the following excerpt concerning license conditions with Constellation from Office of Nuclear Reactor Regulation Office Instruction 101, Revision 6, License Amendment Review Procedure (ML19248C539):

License conditions should:

o Address issues of high safety or regulatory significance; o Be worded such that the meaning is clear and not open to different interpretations; and o Explicitly define the conditions for satisfaction of the condition License conditions should not:

o Addresss issues already addressed by existing rule, requirements, order, or regulation; o Require NRC action to complete; o Be open-ended; o Address a facility not controlled by the licensee; or o Address voluntary requests The NRC staff provided the following feedback regarding license conditions:

the Waterford fiber optic cable EQ precedent cited by Constellation is not an appropriate precedent considering the difference in significance between the Waterford and Limerick modifications the proposed license condition would be satisfied with completion of all actions described in the proposed license condition - not solely by documenting successful completion of testing the equipment, types of tests, and guidance documents concerning EQ testing in the proposed license condition should be consistent with the equipment, types of tests, and guidance documents concerning EQ testing in the licensees license amendment request, if the proposed license condition is to a sufficient substitution for EQ summary test reports for clarity, documents (e.g., test procedures) included in the proposed license condition should have revision numbers and exist at the time the proposed license condition is submitted for review documents included in the proposed license condition will become requirements, so care should be taken when including documents in the proposed license condition During the meeting, the licensees vendor stated that the inclusion of Regulatory Guide 1.209, Guidelines for Environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants, in the license amendment request may have been mistaken.

The NRC staff did not make any regulatory decisions at the meeting. Public Meeting Feedback forms were not received. Members of the public were in attendance. Please direct any inquiries to me at (301) 415-2871, or michael.marshall@nrc.gov.

/RA/

Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

List of Attendees cc: Listserv

Enclosure LIST OF ATTENDEES NOVEMBER 8, 2024, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 U.S. Nuclear Regulatory Commission Constellation Energy Generation, LLC Christina Antonescu Ashley Rickey Eric Miller George Budock Fanta Sacko Gerald Segner Jack Zhao Kayla Marriner Michael Marshall Laura Lynch Matthew McConnell Mark DiRado Samir Darbali Mark Samselski Michael Foote Sailaja Mokkapati Members of the Public Steven Hesse Alan Campbell Mary Miller Westinghouse Dante Mincin Darryl Muetzel Matthew Shakun Parastoo Muse Robert Beasley Suresh Channarasappa Warren Odess-Gillett Sargent and Lundy John Schrage Pareez Golub

Package: ML24338A096 Meeting Notice: ML24312A366 Meeting Handouts: ML24310A260 Meeting Summary: ML24338A092 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME MMarshall KZeleznock HGonzález MMarshall DATE 12/02/2024 12/04/2024 12/04/2024 12/06/2024