ML24339B832

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Constellations December 4, 2024 Presentation About Proposed License Condition for Limerick DMP (Non-Proprietary)
ML24339B832
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 12/04/2024
From:
Constellation Energy Generation
To: Marshall M
NRC/NRR/DORL/LPL1
Klett, AL
References
Download: ML24339B832 (1)


Text

Proposed License Condition for Limerick DMP December 4, 2024

  • To help facilitate NRC review and approval of LAR prior to completion of Equipment Qualification testing
  • Transmittal to NRC will consist of:

-Cover letter

-Attachment 1 - License Conditions (LCs) for Unit 1 and Unit 2.

The LCs will require completion of testing of components listed in, of the installed equipment, prior to startup.

-Attachment 2 Describes the required testing by referencing the applicable Regulatory Guides, EPRI Technical Report, and previously submitted EQ Summary Report, and RAI response.

Includes two tables that list the components and test status that were originally specified in the May 3, 2024 RAI Response, as well as the associated test acceptance criteria, if not previously specific in the RAI Response.

Proposed License Condition (DRAFT) l LGS DMP Proposed License Condition 1

(21)

Equipment Qualification Testing and Analysis - Plant Protection System Components Prior to startup following the first refueling outage during which the digital instrumentation and control (DI&C) Plant Protection System (PPS) at the Limerick Generating Station, Unit 1 (LGS) is installed, Constellation Energy Generation, LLC (CEG) shall complete seismic, environmental, and electromagnetic capability (EMC) testing and analysis of critical hardware components, as described in CEG letter to the U.S. Nuclear Regulatory Commission (NRC), Proposed License Condition - Qualification of Components - Limerick Generating Station Digital Plant Protection System, dated December XX, 2024, Attachment 2, Equipment Qualification of LGS PPS Components. To satisfy this License Condition, CEG will formally document the successful completion of the required EQ testing and analyses described in Attachment 2.

(*) Attachment 1 will also include specific License Condition for Unit 2 Proposed License Condition(*)

l LGS DMP Proposed License Condition 2

Constellation Energy Generation, LLC (CEG) will conduct fault testing of Isolation Barriers that will be installed as part of Limerick Generating Station, Unit 1 and Unit 2 (LGS) Plant Protection System (PPS) modification, as listed in Table 1 below.

The fault testing and analysis of Isolation Barriers, including acceptance criteria, is described in CEG letter to the NRC, 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), dated May 3, 2024 (ADAMS Accession No. ML24124A043) (i.e., the CEG response to RAI 9).

l LGS DMP Proposed License Condition 3

Equipment Qualification of LGS PPS Equipment

CEG will conduct seismic, environmental, and electromagnetic capability (EMC) equipment qualification (EQ) testing and analysis of the hardware components that will be installed as part of LGS PPS modification, including fiber optic cable assemblies as described in Table 2 below.

The EQ testing and analysis process for LGS PPS hardware components is described in EQ-QR-433-GLIM-P, Qualification Summary Report for the Plant Protection System Upgrade for Limerick Units 1 & 2, Revision 4, which was submitted by CEG letter dated June 28, 2024 (ADAMS Accession No. ML24180A157). Seismic, environmental, and EMC testing is described in Sections 3.1.1, Component Seismic Testing, 3.2.1, Component Environmental Testing, and 3.3.1, Component EMC Testing, respectively.

CEG will review and determine EQ testing and analysis requirements for all additional or different hardware components that are incorporated into the LGS PPS design, susbsequent to the date of this letter, in accordance with RG 1.75, Revision 3, RG 1.89, Revision 1, RG 1.100, Revision 3, RG 1.180, Revision 2, and RG 1.209, Revision 0.

l LGS DMP Proposed License Condition 4 (cont.)

Equipment Qualification of LGS PPS Equipment

Seismic qualification testing of the LGS PPS components listed in Table 2 will verify that the components will be capable of operation without loss of safety function or physical integrity, as defined by the seismic acceptance criteria for each component listed in Table 2.

Environmental qualification testing will verify that the LGS PPS components listed in Table 2 will be capable of operation without loss of safety functions, as define by ethe environment acceptance criteria for each component listed in Table 2.

EMC qualification testing will verify that the LGS PPS components listed in Table 2 will meet the requirements specified in RG 1.180, Revision 2, and Electric Power Research Institute (EPRI) Technical Report TR-102323, Revision 4, Guidelines for Electromagnetic Interference Testing in Power Plants and Table 2.

l LGS DMP Proposed License Condition 5 (cont.)

Equipment Qualification of LGS PPS Equipment

l LGS DMP Proposed License Condition 6 (cont.)

Table 1 Isolation Barrier Fault Test Status (examples)

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l LGS DMP Proposed License Condition 7 (cont.)

Table 2 (examples)

LGS PPS Equipment Qualification Test Status

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l LGS DMP Proposed License Condition 8 (cont.)

Table 2 (examples)

LGS PPS Equipment Qualification Test Status

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