ML25037A286
| ML25037A286 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/05/2025 |
| From: | Para W Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25037A284 | List: |
| References | |
| LIM-25-004-NP | |
| Download: ML25037A286 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.ConstellationEnergy.com ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390.
When separated from Attachment 1, this cover letter is decontrolled.
ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 February 5, 2025 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Document Control Desk Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
Subject:
Response to Requests for Confirmatory Information (RCIs 1 through 4) 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)
References: 1. Constellation Energy Generation, LLC (CEG) letter to the U.S. Nuclear Regulatory Commission (NRC), "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 September 26, 2022 (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML22269A569).
2.
Constellation Energy Generation, LLC (CEG) letter to the U.S. Nuclear Regulatory Commission (NRC), "Resubmittal of 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) - To Address Proprietary Issues with INL HFE Reports," dated September 12, 2023 (ADAMS Accession No. ML23255A095) 3.
Email from Michael Marshall, U.S. Nuclear Regulatory Commission to Wendi Para, Constellation Energy Generation, LLC, Limerick Generating Station, Units 1 and 2 - Request for Additional Information and Request for Confirmatory Information Regarding Limerick Digital Instrumentation and Controls License Amendment Request (EPID L-2022-LLA-0140),
dated January 6, 2025 (ADAMS Accession No. ML25007A150 (NP))
In accordance with 10 CFR 50.90, Constellation Energy Generation, LLC (CEG) requested a License Amendment Request (LAR) to replace the Limerick Generating Station, Units 1 and 2 existing safety-related analog control systems with a single digital Plant Protection System (PPS) (Reference 1).
Limerick DMP LAR RCIs 1 through 4 Response Docket Nos. 50-352 and 50-353 February 5, 2025 Page 2 ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 In Reference 2, CEG submitted a LAR supplement that replaced in its entirety the original license amendment request, dated September 26, 2022. CEG replaced the original submittal to address issues associated with proprietary/non-proprietary information.
In Reference 3, the NRC notified CEG that additional information is needed to complete its review of the Reference 2 submittal. to this letter contains the proprietary Westinghouse Electric Company (WEC)
LIM-25-004-P, Revision 0, Limerick Units 1 and 2 Digital Modernization Project, Component Interface Module (CIM) Request for Confirmatory Information (RCI). (Response to RCIs 1-
- 4) to this letter contains the non-proprietary WEC LIM-25-004-NP, Revision 0, Limerick Units 1 and 2 Digital Modernization Project, Component Interface Module (CIM)
Request for Confirmatory Information (RCI). (Response to RCIs 1-4) to this letter contains the WEC proprietary affidavit, CAW-25-001, Revision 0, for Attachment 1. The affidavit is signed by WEC, the owner of the proprietary information.
The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the NRC, and it addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the NRCs regulations. WEC requests that the WEC proprietary information contained in Attachment 1 be withheld from public disclosure in accordance with 10 CFR 2.390. Future correspondence with respect to the proprietary aspects of the application for withholding related to WEC proprietary information or the WEC affidavit provided in the applicable Attachments should reference this request letter.
CEG has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, which was previously provided to the NRC in the Reference 2 letter. CEG has concluded that the information provided in this RCI response does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92. In addition, CEG has concluded that the information in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendments.
This RCI response letter contains no regulatory commitments.
ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390
Limerick DMP LAR RCIs 1 through 4 Response Docket Nos. 50-352 and 50-353 February 5, 2025 Page 3 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"
paragraph (b), CEG is notifying the Commonwealth of Pennsylvania of this supplemental letter by transmitting a copy of this letter to the designated State Official.
If you have any questions regarding this submittal, then please contact Ashley Rickey at Ashley.Rickey@constellation.com.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 5th day of February 2025.
Respectfully, Wendi E. Para Sr. Manager - Licensing Constellation Energy Generation, LLC Attachments: 1. WEC LIM-25-004-P, Revision 0, Limerick Units 1 and 2 Digital Modernization Project, Component Interface Module (CIM) Request for Confirmatory Information (RCI) - Proprietary
- 2. WEC LIM-25-004-NP, Revision 0, Limerick Units 1 and 2 Digital Modernization Project, Component Interface Module (CIM) Request for Confirmatory Information (RCI) - Non-proprietary
USNRC Region I, Regional Administrator w/ attachments USNRC Project Manager, LGS USNRC Senior Resident Inspector, LGS Director, Bureau of Radiation Protection - Pennsylvania w/o attachment 1 Department of Environmental Protection Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 WEC LIM-25-004-NP, Revision 0, Limerick NRC Equipment Qualification Request for Confirmatory Information, (Response to RCIs 1 through 4) - Non-proprietary
©2025 Westinghouse Electric Company LLC. All Rights Reserved Electronically Approved Records Are Authenticated in the Electronic Document Management System Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Mr. Jerry Segner Principal Project Manager Constellation Energy Generation, LLC Limerick Generating Station 3146 Sanatoga Road Pottstown, PA 19464 jerry.segner@constellation.com Direct Telephone:
(860) 731-6260 E-mail:
shakunma@westinghouse.com Contract:
00800304 Sales Order:
156102 Our Ref:
LIM-25-004-NP, Rev. 0 January 30, 2025 CONSTELLATION ENERGY GENERATION LIMERICK UNITS 1 AND 2 DIGITAL MODERNIZATION PROJECT Component Interface Module (CIM) Request for Confirmatory Information (RCI)
Dear Mr. Segner:
The following provides Westinghouses confirmations and clarifications to RCIs 1 - 4.
RCI-1 The description of the CIM is correct for the areas that are discussed. It should be noted that every function in the CIM is not required for the CIM to provide the functions required by the D3 analysis. The modules that are used to implement the FPGA logic are designed to provide functional separation between the functions in the CIM. The functional separation provides a robust design by minimizing the interaction between the functions in the CIM. For example, the LED indications read the status of the signals, and do not affect the CIM output or the feedback status.
[
]a,c Westinghouse Non-Proprietary Class 3
Westinghouse Non-Proprietary Class 3 Page 2 of 4 Our Ref: LIM-25-004-NP, Rev. 0
[
]a,c Additional information will be provided in the RAI responses to clarify how the modules in the CIM work together to perform the functions that are required to support the D3 analysis.
RCI-2 The summary of the architecture is correct.
RCI-3 The summary of the CIM is correct.
Westinghouse Non-Proprietary Class 3 Page 3 of 4 Our Ref: LIM-25-004-NP, Rev. 0 RCI-4 The summary of architecture of the AP1000 and Limerick designs is correct. It should be noted that the AP1000 design also uses the Z-Port for some components. It is used to Block the Safety System commands under certain plant conditions. The following updated illustration shows this signal path for the AP1000 design.
If you have any questions or require additional information regarding this transmittal, please feel free to contact me at (860) 731-6260.
Sincerely, WESTINGHOUSE ELECTRIC COMPANY LLC Electronically Approved Author: Matthew Shakun, Principal Licensing Engineer Reviewer: Thomas Tweedle, Fellow Engineer Approver: Jerrod Ewing, Manager a,c
Westinghouse Non-Proprietary Class 3 Page 4 of 4 Our Ref: LIM-25-004-NP, Rev. 0 cc: Constellation Energy Steven Hesse steven.hesse@constellation.com Kayla Marriner kaylalover.marriner@constellation.com Zina Gavin zina.gavin@constellation.com Mark Samselski mark.samselski@constellation.com Ashley Rickey ashley.rickey@constellation.com Westinghouse Electric Company LLC Courtney Frank Parastoo Muse Andrew Lutz Steve Merkiel Andrew Barth Cynthia Olesky Steven Seaman Warren Odess-Gillett Matthew Shakun Limerick Generating Station, Units 1 and 2 Docket Nos. 50-352 and 50-353 WEC Proprietary Affidavit, CAW-25-001, Revision 0, for Attachment 1
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-001 Page 1 of 3 Commonwealth of Pennsylvania:
County of Butler:
(1)
I, Jerrod Ewing, Manager, Operating Plants Licensing, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).
(2)
I am requesting the proprietary portions of LIM-25-004-P be withheld from public disclosure under 10 CFR 2.390.
(3)
I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.
(4)
Pursuant to 10 CFR 2.390, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)
The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.
(ii)
The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.
(iii)
Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-001 Page 2 of 3 (5)
Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a)
The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
(6)
The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-001 Page 3 of 3 I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.
Executed on: 1/29/2025 Signed electronically by Jerrod Ewing