ML25188A208
| ML25188A208 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/09/2025 |
| From: | Robert Davis Plant Licensing Branch 1 |
| To: | Constellation Energy Generation |
| References | |
| EPID L-2025-LRM 0034 | |
| Download: ML25188A208 (1) | |
Text
July 9, 2025 LICENSEE:
Constellation Energy Generation, LLC FACILITY:
Limerick Generating Station, Units 1 & 2
SUBJECT:
SUMMARY
OF JUNE 26, 2025, PUBLIC OBSERVATION MEETING WITH CONSTELLATION ENERGY GENERATION TO DISCUSS A PLANNED LICENSE AMENDMENT REQUEST FOR A ONE TIME EXTENSION TO THE INTEGRATED LEAKRATE TEST FOR LIMERICK GENERATING STATION, UNITS 1 AND 2 (EPID L-2025-LRM-0034)
On June 26, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff held a virtual preapplication meeting with representatives from Constellation Energy Generation, LLC (Constellation, the licensee) to discuss a proposed license amendment request (LAR) concerning a one-time extension of the Type A integrated leak rate test (ILRT) interval for Limerick Generating Station, Units 1 and 2. The meeting notice and agenda, dated June 13, 2025, are available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML25177B155. The enclosure to this summary contains a list of attendees. The licensees presentation slides are available in ADAMS at ML25177A031.
During the meeting, Constellation provided an overview of the planned extension, which seeks to move the next required ILRT for Unit 1 from April 2027 to April 2028 and for Unit 2 from April 2028 to April 2029, in order to support the digital modernization project (DMP) scheduled to be implemented during the upcoming outage. The licensee outlined the technical and logistical justifications for this request, emphasizing the scope and complexity of the DMP and the goal of maintaining a focused and efficient outage schedule. Constellation also reviewed proposed technical specification changes and provided background on prior ILRT performance, risk assessments, and containment inspection programs.
NRC staff stated that the application, if submitted, should include a thorough risk evaluation addressing all standard regulatory conditions for ILRT extensions, consistent with the guidance in Nuclear Energy Institute (NEI) 94-01. The NRC staff also suggested that the submittal provides a detailed discussion of any impacts the DMP may have on local leak rate tests (Type B and C), including how valve and lineup changes during the DMP may affect testing or procedure modifications. NRC staff asked for a clear explanation of why this extension is justified under current regulatory guidance (NEI 94-01, Regulatory Issue Summary (RIS) 2008-27), and requested that prior ILRT, Type B, and Type C performance results, as well as relevant inspection findings, be included in the submittal to support the risk assessment.
NRC staff inquired whether the DMP would require changes to the performance of local leak rate tests; Constellations representatives responded that while control systems are being upgraded, no direct changes to valve hardware or testing frequencies are anticipated, and any procedural modifications would be described in the LAR. NRC staff also suggested that Constellation use the term exception rather than exemption in the changes to the technical specifications to avoid regulatory confusion. Constellation committed to addressing all NRC information needs in their forthcoming submittal, including a comprehensive risk assessment, documentation of historical containment test performance, a discussion of containment inspection results, and an explanation of how the extension supports plant safety during the DMP implementation. The licensee stated that it plans to submit the LAR in early July 2025, with a request for NRC approval by March 31, 2026, to support the spring 2026 refueling outage for Limerick, Unit 1. Constellation also stated that they would continue to prepare for the ILRT as scheduled, while simultaneously progressing with the DMP and the LAR submission.
The NRC staff did not make any regulatory decisions at the meeting. Members of the public were not in attendance.
Please direct any inquiries to me at (301) 415-0805, or 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. 50-352 and 50-353
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES JUNE 26, 2025, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC LIMERICK GENERATING STATION, UNITS 1 & 2 Brian Lee U.S. Nuclear Regulatory Commission (NRC)
Gurjendra Bedi NRC Hanry Wagage NRC Hipo Gonzalez NRC Ian Tseng NRC Jay Robinson NRC Joshua Wilson NRC Lundy Pressley NRC Michael Marshall NRC Milton Valentin NRC Rachael Davis NRC Shao Lai NRC Si Hwan Park NRC Brian Wysowski Constellation Energy Generation, LLC (Constellation)
Casey Coyle Constellation Connelly Richards Constellation Craig Hoffman Constellation Evan Dimmerling Constellation Jordan Rajan Constellation Kevin Cawley Constellation Lane Oberembt Constellation Lorrha Hitchner Constellation Renee Guy Constellation Scott Schumacher Constellation Stephen Deihm Constellation Stephen Flickinger Constellation Wendi Para Constellation Grant Teagarden Jensen Hughes
ML25188A208 (Meeting Summary)
OFFICE NRR/DORL/LDATA/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/DATA/PM NAME RDavis KEntz HGonzález RDavis DATE 07/07/2025 7/8/2025 07/08/2025 07/09/2025