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| {{#Wiki_filter:Limerick Generating Station Digital Modernization Project Acceptance Review Follow-up on IEEE-603 Compliance Issues December 15, 2022 | | {{#Wiki_filter:Limerick Generating Station Digital Modernization Project Acceptance Review Follow-up on IEEE-603 Compliance Issues |
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| CEG Participants | | December 15, 2022 CEG Participants |
| * Licensing | | * Licensing |
| * Dave Helker, Licensing Manager | | * Dave Helker, Licensing Manager |
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| * Jim Berg, Site Regulatory Assurance | | * Jim Berg, Site Regulatory Assurance |
| * Engineering | | * Engineering |
| - John Connelly, Central Design Organization (CDO) Manager
| | - John Connelly, Central Design Organization (CDO) Manager |
| - Mark Samselski, CDO - Lead Responsible Engineer
| | - Mark Samselski, CDO - Lead Responsible Engineer |
| - George Bonanni, CDO - Senior Staff Engineer
| | - George Bonanni, CDO - Senior Staff Engineer |
| - Scott Schumacher, Systems Engineering
| | - Scott Schumacher, Systems Engineering |
| * WEC | | * WEC |
| - Warren Odess-Gillett, WEC Licensing Lead 1
| | - Warren Odess-Gillett, WEC Licensing Lead |
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| Opening Remarks | | 1 Opening Remarks |
| * NRC | | * NRC |
| * CEG 2 | | * CEG |
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| Acceptance Review Letter- IEEE 603 Compliance | | 2 Acceptance Review Letter-IEEE 603 Compliance |
| * Items 2 and 3: Exceptions to IEEE-603-1991 | | * Items 2 and 3: Exceptions to IEEE-603-1991 |
| * At the public meeting, the staff noted that the IEEE-603-1991 clauses that Constellation is taking exception to correspond to similar requirements in IEEE Standard 279-1968 that are required to be met for proposed protection systems at Limerick in accordance with 10 CFR 55.55a(h)(2). Taking exception to the clauses in IEEE-603-1991 would seem to indicate that the system planned for Limerick would not comply with 10 CFR 55.55 a(h)(2), in which case the system could not be approved without additional licensing actions (e.g., requesting an exemption or alternative request). As justification for the exception, the LAR references, and Constellation discussed at the public meeting, Limericks updated final safety analysis report (UFSAR) and emergency operating procedures. However, the staff could not identify a clear regulatory basis for the exceptions in these references during the acceptance review period. | | * At the public meeting, the staff noted that the IEEE-603-1991 clauses that Constellation is taking exception to correspond to similar requirements in IEEE Standard 279-1968 that are required to be met for proposed protection systems at Limerick in accordance with 10 CFR 55.55a(h)(2). Taking exception to the clauses in IEEE-603-1991 would seem to indicate that the system planned for Limerick would not comply with 10 CFR 55.55 a(h)(2), in which case the system could not be approved without additional licensing actions (e.g., requesting an exemption or alternative request). As justification for the exception, the LAR references, and Constellation discussed at the public meeting, Limericks updated final safety analysis report (UFSAR) and emergency operating procedures. However, the staff could not identify a clear regulatory basis for the exceptions in these references during the acceptance review period. |
| * While follow up is necessary to determine if the licensing basis documents provide sufficient justification, the staff concluded that resolution of these issues was not necessary to support acceptance of the LAR because Constellation had provided a justification for the exceptions. Because the staff has not been able to verify the adequacy of the justification through its review of the information provided to date, this issue is a high priority licensing concern that needs to be addressed by Constellation. | | * While follow up is necessary to determine if the licensing basis documents provide sufficient justification, the staff concluded that resolution of these issues was not necessary to support acceptance of the LAR because Constellation had provided a justification for the exceptions. Because the staff has not been able to verify the adequacy of the justification through its review of the information provided to date, this issue is a high priority licensing concern that needs to be addressed by Constellation. |
| * The staff will discuss this issue further at the public meeting with Constellation scheduled for December 15, 2022, to identify an appropriate regulatory path forward. | | * The staff will discuss this issue further at the public meeting with Constellation scheduled for December 15, 2022, to identify an appropriate regulatory path forward. |
| Possible paths include the staff issuing a request for additional information as part of its detailed review of the LAR, or Constellation providing supplemental information or an 3 | | Possible paths include the staff issuing a request for additional information as part of its detailed review of the LAR, or Constellation providing supplemental information or an additional licensing action requesting an exemption or alternative request. |
| additional licensing action requesting an exemption or alternative request. | | 3 Vendor Oversight |
| | |
| Vendor Oversight | |
| * Constellations Vendor Oversight Plan (VOP) was executed during review. | | * Constellations Vendor Oversight Plan (VOP) was executed during review. |
| * The plan requires the execution of Constellations Owners Acceptance Review of External Technical Products Procedure. | | * The plan requires the execution of Constellations Owners Acceptance Review of External Technical Products Procedure. |
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| * The typo identified for IEEE 603 Clause 5.6.1 was not identified by reviewers. | | * The typo identified for IEEE 603 Clause 5.6.1 was not identified by reviewers. |
| * The following actions were taken per the VOP to ensure high quality: | | * The following actions were taken per the VOP to ensure high quality: |
| - An entry into Constellations Supplier Fundamental Management System (SFMS)
| | - An entry into Constellations Supplier Fundamental Management System (SFMS) |
| - An entry into the VOP Action Tracking Item Assignment System (ATI 04456784) to formally track completion and results of the vendors Corrective Action Program Issue Report (CAP-2022-10020).
| | - An entry into the VOP Action Tracking Item Assignment System (ATI 04456784) to formally track completion and results of the vendors Corrective Action Program Issue Report (CAP-2022-10020). |
| - Review results of the issue report
| | - Review results of the issue report |
| - Ensure LTR is revised 4
| | - Ensure LTR is revised |
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| IEEE 603 Clauses 6.6 & 7.4 | | 4 IEEE 603 Clauses 6.6 & 7.4 |
| * Constellation provided comments to ensure EOPs and SAGs overrides are described appropriately in the LTR during the review process. | | * Constellation provided comments to ensure EOPs and SAGs overrides are described appropriately in the LTR during the review process. |
| * Subsequent to the first Acceptance Review Meeting, the Constellation team reached out to industry experts to aid in the understanding of the Operating Bypass definition in the context of EOPs and SAGs. | | * Subsequent to the first Acceptance Review Meeting, the Constellation team reached out to industry experts to aid in the understanding of the Operating Bypass definition in the context of EOPs and SAGs. |
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| == Conclusion:== | | == Conclusion:== |
| LTR miscategorized overrides as operating bypasses. This will be corrected in next LTR revision. | | LTR miscategorized overrides as operating bypasses. This will be corrected in next LTR revision. |
| 5
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| What is an Operating Bypass? | | 5 What is an Operating Bypass? |
| * According to IEEE Std 603-1991, an operating bypass is used to permit plant mode changes: | | *According to IEEE Std 603-1991, an operating bypass is used to permit plant mode changes: |
| * With this definition for operating bypass, all PPS operating bypasses meet the criteria in both IEEE Std 279 and 603, the bypass will be removed automatically whenever permissive conditions are not met. [IEEE Std 279]. | | * With this definition for operating bypass, all PPS operating bypasses meet the criteria in both IEEE Std 279 and 603, the bypass will be removed automatically whenever permissive conditions are not met. [IEEE Std 279]. |
| * Overrides in the Limerick EOPs and SAGs are not operating bypasses per the definition in IEEE Std 603-1991 and therefore this criteria in IEEE Std 279 and 603 does not apply. | | *Overrides in the Limerick EOPs and SAGs are not operating bypasses per the definition in IEEE Std 603-1991 and therefore this criteria in IEEE Std 279 and 603 does not apply. |
| * With this decision of full compliance, there will be no action to request alternate compliance via 10CFR50.55(a)(z), as discussed during previous Acceptance Review Meeting held on November 10, 2022. | | *With this decision of full compliance, there will be no action to request alternate compliance via 10CFR50.55(a)(z), as discussed during previous Acceptance Review Meeting held on November 10, 2022. |
| 6
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| Changes to the Licensing Technical Report (LTR) | | 6 Changes to the Licensing Technical Report (LTR) |
| * Accordingly, the LTR (WCAP-18598) will be revised. | | * Accordingly, the LTR (WCAP-18598) will be revised. |
| * Compliance to IEEE Std 603 Table ( Section 7) for Clause 5.6.1 will be changed from PC to C. | | * Compliance to IEEE Std 603 Table ( Section 7) for Clause 5.6.1 will be changed from PC to C. |
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| * It is expected that additional changes will also be incorporated into LTR during the final design process and during the RAI process, with goal of updating these and the above in Spring 2023. | | * It is expected that additional changes will also be incorporated into LTR during the final design process and during the RAI process, with goal of updating these and the above in Spring 2023. |
| * The revised LTR will be submitted on the docket when completed. | | * The revised LTR will be submitted on the docket when completed. |
| 7
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| Changes to the Licensing Technical Report (LTR) 8 | | 7 Changes to the Licensing Technical Report (LTR) |
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| | 8 Changes to the Licensing Technical Report (LTR) |
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| Changes to the Licensing Technical Report (LTR)
| | Table 7-1 Compliance/Conformance Matrix for IEEE Std 603 and IEEE Std 7-4.3.2 |
| Table 7-1 Compliance/Conformance Matrix for IEEE Std 603 and IEEE Std 7-4.3.2 IEEE IEEE Title Compliance/ Section(s) | |
| Std Std 7- Conformance 603 4.3.2 Clause Clause 5.6.1 Between Redundant Portions PC C 3.5.14.1 of a Safety System 6.6 6* Operating Bypasses EC 3.3.2.8 7.4 Operating Bypass EC 3.3.2.8 7*
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| 9
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| Close Out Remarks | | IEEE IEEE Title Compliance/ Section(s) |
| | Std Std 7-Conformance 603 4.3.2 Clause Clause 5.6.1 Between RedundantPortions PC C 3.5.14.1 ofaSafetySystem |
| | |
| | 6.6 6* OperatingBypasses EC 3.3.2.8 7.4 7* Operating Bypass EC 3.3.2.8 |
| | |
| | 9 Close Out Remarks |
| * Questions? | | * Questions? |
| * Next Steps? | | * Next Steps? |
| * Final Remarks | | * Final Remarks |
| * CEG | | * CEG |
| * NRC 10}} | | * NRC |
| | |
| | 10}} |
Letter Sequence Meeting |
|---|
EPID:L-2022-LLA-0140, Review of Limerick Generating Station Defense in Depth and Diversity Common Cause Failure Coping Analysis, WNA-AR-01074-GLIM-P, Rev 1. Without Attachment 3 Enclosure (Open) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance, Acceptance, Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
|
MONTHYEARML22046A0742022-02-14014 February 2022
Review of Limerick Generating Station Defense in Depth and Diversity Common Cause Failure Coping Analysis, WNA-AR-01074-GLIM-P, Rev 1. Without Attachment 3 Enclosure
Project stage: Request
PMNS20220709, Meeting Between NRC Staff and Constellation Energy Generation, LLC on the Review of the Defense-in-Depth and Diversity Coping Analysis Supporting the Digital Upgrade of Instrumentation and Controls at Limerick Generating Station, Units2022-07-22022 July 2022
Meeting Between NRC Staff and Constellation Energy Generation, LLC on the Review of the Defense-in-Depth and Diversity Coping Analysis Supporting the Digital Upgrade of Instrumentation and Controls at Limerick Generating Station, Units 1 an
Project stage: Request
ML22224A1492022-08-15015 August 2022
Review of Limerick Generating Station Defense in Depth and Diversity Common Cause Failure Coping Analysis, WNA-AR-01074-GLIM-P, Revision 2, July 2022, and the Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital
Project stage: Request
ML23009A5622022-11-0707 November 2022, 14 November 2022, 11 January 2023
Summary of December 15, 2022 Public Meeting on Limeric Digital I&C LAR Acceptance
Project stage: Request
PMNS20221157, Meeting Between NRC and Constellation Energy Generation, LLC Regarding Ongoing Acceptance Review of Limerick Generating Station, Units 1 and 2 Digital Instrumentation and Controls License Amendment Request2022-11-0707 November 2022
Meeting Between NRC and Constellation Energy Generation, LLC Regarding Ongoing Acceptance Review of Limerick Generating Station, Units 1 and 2 Digital Instrumentation and Controls License Amendment Request
Project stage: Acceptance Review
ML22340A2172022-11-10010 November 2022, 21 November 2022, 6 December 2022
Summary of November 10, 2022, Meeting with Constellation Energy Generation, Lic on Acceptance Review of Limerick Digital Instrumentation and Controls License Amendment Requests
Project stage: Request
ML22312A4402022-11-10010 November 2022
Public Meeting with Constellation About Acceptance Review: Status of NRC Staffs Acceptance Review of the Limerick Digital Instrumentation and Controls License Amendment Request
Project stage: Acceptance Review
ML22319A0012022-11-14014 November 2022
Constellation Energy Generation, LLCs Presentation for November 10, 2022 Public Meeting with NRC
Project stage: Request
ML22320A1132022-11-21021 November 2022
Generation Station, Units 1 and 2 - Supplemental Information Needed for Acceptance of Digital Instrumentation and Controls License Amendment Requests
Project stage: Acceptance Review
ML22333A8172022-11-29029 November 2022
Response to Supplemental Information Needed for Acceptance of Digital Instrumentation and Controls License Amendment Requests for the Limerick Generating Station
Project stage: Supplement
ML22327A0192022-12-0606 December 2022
Summary of November 10, 2022, Meeting with Constellation Energy Generation, Lic on Acceptance Review of Limerick Digital Instrumentation and Controls License Amendment Requests
Project stage: Acceptance Review
ML22339A0642022-12-0909 December 2022
Generation Station, Unit Nos. 1 and 2 – Acceptance of Requested Licensing Action Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System
Project stage: Acceptance Review
ML22347A1532022-12-13013 December 2022
Public Meeting Presentation, December 15, 2022 Di&C License Amendment Request
Project stage: Meeting
ML23003A1702022-12-15015 December 2022
Official Transcript of the 12/15/22 Meeting with Constellation Energy to Discuss the Exceptions Described for the Independence and Operating Bypass with IEEE 603 of the Proposed Plant Protection System in the Limerick Station, Units 1 and 2
Project stage: Meeting
ML23009A5872023-01-11011 January 2023
Summary of December 15, 2022, Meeting with Constellation Energy Generation, LLC on Potential Compliance with Certain Clauses of IEEE Standard 603-1991 in Limerick Digital Instrumentation and Controls License Amendment Requests
Project stage: Meeting
ML22353A6322023-01-17017 January 2023
Supplement to Regulatory Audit Plan in Support of Review of Digital I&C Upgrade to Protection Systems (EPID L-2022-LLA-0140) - Non-Proprietary
Project stage: Other
PMNS20230026, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-01-20020 January 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23076A1062023-01-20020 January 2023, 12 May 2023
Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
ML23032A2442023-02-0606 February 2023
Regulatory Audit Plan for Review of Human Factors Engineering Portion of Limerick Digital Instrumentation and Controls License Amendment Request
Project stage: Other
ML23039A1412023-02-0808 February 2023
Supplement to 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)-Human Factors Engineering
Project stage: Supplement
ML23046A2662023-02-15015 February 2023
Supplement to 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
Project stage: Supplement
PMNS20230032, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-02-23023 February 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
PMNS20230033, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-03-0606 March 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23121A0042023-03-0606 March 2023, 12 May 2023
Summary of March 29, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
ML23118A3792023-03-17017 March 2023, 9 June 2023
April 12, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
PMNS20230254, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-03-17017 March 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23089A3242023-03-30030 March 2023
Supplement to 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 Human Factors Engine
Project stage: Supplement
ML23095A2232023-04-0505 April 2023
Supplement to 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)- Human Factors
Project stage: Supplement
PMNS20230423, Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-04-17017 April 2023
Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23132A3092023-04-17017 April 2023, 18 May 2023
Summary of May 3, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
ML23076A1042023-05-12012 May 2023
Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23076A0132023-05-12012 May 2023
March 15, 2023, Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23121A0022023-05-12012 May 2023
Summary of March 29, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23145A0672023-05-15015 May 2023, 31 May 2023
May 17, 2023, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
PMNS20230627, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-05-15015 May 2023
Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
PMNS20230606, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-05-16016 May 2023
Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23156A4172023-05-16016 May 2023, 9 June 2023
Summary of May 24, 2023, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Request
ML23132A3082023-05-18018 May 2023
Summary of May 3, 2023, Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23143A3422023-05-23023 May 2023
Supplement to 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
Project stage: Supplement
ML23145A0352023-05-31031 May 2023
Summary of May 17, 2023, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23118A3752023-06-0909 June 2023
Summary of Audit Meeting with Constellation Energy Generation Concerning a Digital Instrumentation and Control Upgrade License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23156A2472023-06-0909 June 2023
Summary of Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23177A2242023-06-26026 June 2023
Supplement to 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 .
Project stage: Supplement
PMNS20230846, Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 22023-07-18018 July 2023
Meeting with Constellation Energy Generation, LLC Regarding Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
Project stage: Meeting
ML23187A0962023-07-19019 July 2023
Generation Station, Unit Nos. 1 and 2 - Revised Estimated Review Completion Date Concerning License Amendment Request to Replace Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System
Project stage: Other
2023-02-23
[Table View] |
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|---|
Category:Meeting Briefing Package/Handouts
MONTHYEARML24310A2602024-11-0808 November 2024
Constellations Presentation on Proposed License Condition for Limerick DMP (EPID L-2022-LLA-0140) (Non-Proprietary)
ML24137A1882024-05-16016 May 2024
Annual Assessment Meeting for Pa/Md/Ny/Nj Nuclear Power Plants - NRC Presentation Slides
ML24100A7672024-04-11011 April 2024
Meeting Slides - Preapplication with Constellation on Planned Fleet Alternative Request to Adopt OMN-2
ML24089A2612024-04-0909 April 2024
Slides - Constellation - Pre-Application Regarding Hooded Masks 4/9/2024 Meeting Slides (L-2024-LLM-0041)
ML24029A1742024-01-30030 January 2024
Constellation Pre-Application January 30, 2024, Meeting Slides - Proposed Alternative to Utilize Code Case N-932, Alternative Requirements for Acceptance of Containment Base Metal Corrosion or Erosion
ML23317A0712023-11-14014 November 2023
NRC Pre-Submittal Meeting on November 14th, 2023 - TSTF-591 and Selected 50.69 License Condition Updates (EPID L-2023-LLM-0098) (Slides)
ML23255A1042023-08-11011 August 2023
Slides - Constellation - Pre-Application EP 9/18/2023 Draft CEG Presubmittal SG Performance Monitoring Plan Meeting Handout
ML23157A0352023-06-0606 June 2023
Annual Assessment Meeting for Pa/Md/Ny/Nj Nuclear Power Plants - NRC Presentation Slides
ML23076A2812023-02-23023 February 2023
Licensee Presentation on Pressure Boundary Process
ML23053A1562023-02-23023 February 2023
NRC Presentation Slides for Public Meeting on February 23, 2023 - 10 CFR 50.69 Alternate Processes License Amendment Request Preliminary Partial Denial
ML23076A2822023-02-23023 February 2023
Licensee Presentation on Defense-in-Depth Process
ML23006A2572023-01-10010 January 2023
Digital Modernization Project Installation Support License Amendment Request and Exemption Request Presentation - January 10, 2023 (EPID L-2022-LRM-0099) (Slides)
ML22347A1532022-12-13013 December 2022
Public Meeting Presentation, December 15, 2022 Di&C License Amendment Request
ML22319A0012022-11-14014 November 2022
Constellation Energy Generation, LLCs Presentation for November 10, 2022 Public Meeting with NRC
ML22312A4402022-11-10010 November 2022
Public Meeting with Constellation About Acceptance Review: Status of NRC Staffs Acceptance Review of the Limerick Digital Instrumentation and Controls License Amendment Request
ML22249A0972022-09-0808 September 2022
Constellations Open Presentation for September 8, 2022 Partially Closed Public Meeting
ML22250A4372022-09-0808 September 2022
NRC Staffs Presentation for September 8, 2022 Partially Closed Public Meeting with Constellation - Review Planning and Tentative Review Timeline
ML22249A2202022-09-0606 September 2022
Constellations Non-Proprietary Presentation for Limerick Generating Station Digital Modernization Project LAR Pre-submittal Meeting September 8, 2022
ML22164A8082022-06-13013 June 2022
Westinghouse, Presentation GLIMM-RPS-PM-L1-000008, Revision 0
ML22153A3602022-06-0909 June 2022
Constellations Presentation for June 9, 2022 Public Meeting About Limerick Generating Station Digital Modernization Project
ML22187A0652022-06-0808 June 2022
Joint Annual Assessment Meeting for Pa/Md/Nj/Ny Nuclear Power Plants - NRC Presentation Slides
ML22103A2542022-04-19019 April 2022
Draft Request for Additional Information
ML22076A1942022-03-23023 March 2022
Constellation Presentation March 23, 2022 NRC Di_C Workshop
ML22080A1522022-03-21021 March 2022
Non-Proprietary Presentation for March 31, 2022 Pre-Submittal Meeting with Constellation Energy Generation, LLC Regarding Planned Digital Modernization License Amendment Request for Limerick Generating Station, Units 1 and 2
ML22010A0692022-01-10010 January 2022
Jan 11 2022 LGS Digital Modernization Pre-submittal Meeting Slides
ML21335A0772021-12-0707 December 2021
Dec 07 2021 LGS Digital Modernization Pre-submittal Meeting Slides
ML21294A3692021-11-15015 November 2021
Summary of October 6, 2021, Public Observation Meeting with Exelon Generation Company, LLC Proposed License Amendment Request to Modify Emergency Diesel Generator and Emregency Core Cooling System Surveillance Requirements
ML21314A4472021-11-10010 November 2021
Slides for Presubmittial Meeting for Proposed Alternative to Adopt ASME Code Case N-921 to Extend the Inservice Inspection Interval
ML21278A5452021-10-20020 October 2021
Digital Modernization Project LAR Pre-submittal Meeting Presentation Slides October 20, 2021
ML21174A0852021-06-23023 June 2021
Digital Modernization Project LAR Pre-submittal Meeting
ML21165A1942021-06-16016 June 2021
Joint Annual Assessment Meeting for Pa/Md/Nj/Ny Nuclear Power Plants - Webinar Presentation
ML21165A2882021-06-16016 June 2021
Joint Annual Assessment for Pa/Md/Nj/Ny Nuclear Power Plants - Webinar Presentation (Updated)
ML21063A1192021-03-0404 March 2021
Digital Modernization Project LAR Pre-submittal Meeting - March 16, 2021 (EPID L-2020-LRM-0041) (Slides)
ML21049A3102021-02-19019 February 2021
CFR 50.69 Alternative Categorization LAR
ML21034A6032021-02-0303 February 2021
External Presentation Am Connelly_ISG-6 Workshop Presentation
ML20261G7322020-09-16016 September 2020
Pre-Submittal Slides Extend 120-month Isi/Ist Interval Under 50.55a
ML20178A4202020-06-30030 June 2020
NEI Slides for June 30, 2020, Public Meeting on COVID-19 Response
ML20175A8722020-06-23023 June 2020
Risk-Informed Inservice Inspection - U.S Nuclear Regulatory Commission (NRC) - Four Element Risk-Informed Approach
ML20170B0212020-06-23023 June 2020
NRC Pre-Submittal Meeting Byron Unit 2 One-Time Deferral of Reactor Pressure Vessel Head Penetration Nozzle (Rpvhpn) Inspections
ML20169A5592020-06-16016 June 2020
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[Table view]
Category:Slides and Viewgraphs
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[Table view] |
Text
Limerick Generating Station Digital Modernization Project Acceptance Review Follow-up on IEEE-603 Compliance Issues
December 15, 2022 CEG Participants
- Dave Helker, Licensing Manager
- Frank Mascitelli, Licensing Lead
- Ashley Rickey, Licensing Engineer
- Pareez Golub, Digital Licensing SME
- Jim Berg, Site Regulatory Assurance
- John Connelly, Central Design Organization (CDO) Manager
- Mark Samselski, CDO - Lead Responsible Engineer
- George Bonanni, CDO - Senior Staff Engineer
- Scott Schumacher, Systems Engineering
- Warren Odess-Gillett, WEC Licensing Lead
1 Opening Remarks
2 Acceptance Review Letter-IEEE 603 Compliance
- At the public meeting, the staff noted that the IEEE-603-1991 clauses that Constellation is taking exception to correspond to similar requirements in IEEE Standard 279-1968 that are required to be met for proposed protection systems at Limerick in accordance with 10 CFR 55.55a(h)(2). Taking exception to the clauses in IEEE-603-1991 would seem to indicate that the system planned for Limerick would not comply with 10 CFR 55.55 a(h)(2), in which case the system could not be approved without additional licensing actions (e.g., requesting an exemption or alternative request). As justification for the exception, the LAR references, and Constellation discussed at the public meeting, Limericks updated final safety analysis report (UFSAR) and emergency operating procedures. However, the staff could not identify a clear regulatory basis for the exceptions in these references during the acceptance review period.
- While follow up is necessary to determine if the licensing basis documents provide sufficient justification, the staff concluded that resolution of these issues was not necessary to support acceptance of the LAR because Constellation had provided a justification for the exceptions. Because the staff has not been able to verify the adequacy of the justification through its review of the information provided to date, this issue is a high priority licensing concern that needs to be addressed by Constellation.
- The staff will discuss this issue further at the public meeting with Constellation scheduled for December 15, 2022, to identify an appropriate regulatory path forward.
Possible paths include the staff issuing a request for additional information as part of its detailed review of the LAR, or Constellation providing supplemental information or an additional licensing action requesting an exemption or alternative request.
3 Vendor Oversight
- Constellations Vendor Oversight Plan (VOP) was executed during review.
- The plan requires the execution of Constellations Owners Acceptance Review of External Technical Products Procedure.
- Constellation provided comments to ensure Emergency Operating Procedures (EOPs) and Severe Accident Guidelines (SAGs) overrides are described appropriately in the Licensing Technical Report (LTR).
- The typo identified for IEEE 603 Clause 5.6.1 was not identified by reviewers.
- The following actions were taken per the VOP to ensure high quality:
- An entry into Constellations Supplier Fundamental Management System (SFMS)
- An entry into the VOP Action Tracking Item Assignment System (ATI 04456784) to formally track completion and results of the vendors Corrective Action Program Issue Report (CAP-2022-10020).
- Review results of the issue report
- Ensure LTR is revised
4 IEEE 603 Clauses 6.6 & 7.4
- Constellation provided comments to ensure EOPs and SAGs overrides are described appropriately in the LTR during the review process.
- Subsequent to the first Acceptance Review Meeting, the Constellation team reached out to industry experts to aid in the understanding of the Operating Bypass definition in the context of EOPs and SAGs.
- Discussions with IEEE standards working group members identified that Operating Bypasses, by definition, permit plant mode changes in IEEE 603-1991 & IEEE-279.
- Further review of the application of EOPs and SAGs in the PPS revealed that these features do not permit plant mode changes.
- The logic developed to support the EOPs and SAGs are overrides to ensure the appropriate safety function can be executed.
Conclusion:
LTR miscategorized overrides as operating bypasses. This will be corrected in next LTR revision.
5 What is an Operating Bypass?
- According to IEEE Std 603-1991, an operating bypass is used to permit plant mode changes:
- With this definition for operating bypass, all PPS operating bypasses meet the criteria in both IEEE Std 279 and 603, the bypass will be removed automatically whenever permissive conditions are not met. [IEEE Std 279].
- With this decision of full compliance, there will be no action to request alternate compliance via 10CFR50.55(a)(z), as discussed during previous Acceptance Review Meeting held on November 10, 2022.
6 Changes to the Licensing Technical Report (LTR)
- Compliance to IEEE Std 603 Table ( Section 7) for Clause 5.6.1 will be changed from PC to C.
- The Compliance/Conformance indication in the IEEE Std 603 Compliance Table (Section 7) for Clauses 6.6 and 7.4 will change from E to C.
- Section 3.3.2.8 will be revised as shown on the next slide.
- It is expected that additional changes will also be incorporated into LTR during the final design process and during the RAI process, with goal of updating these and the above in Spring 2023.
- The revised LTR will be submitted on the docket when completed.
7 Changes to the Licensing Technical Report (LTR)
8 Changes to the Licensing Technical Report (LTR)
Table 7-1 Compliance/Conformance Matrix for IEEE Std 603 and IEEE Std 7-4.3.2
IEEE IEEE Title Compliance/ Section(s)
Std Std 7-Conformance 603 4.3.2 Clause Clause 5.6.1 Between RedundantPortions PC C 3.5.14.1 ofaSafetySystem
6.6 6* OperatingBypasses EC 3.3.2.8 7.4 7* Operating Bypass EC 3.3.2.8
9 Close Out Remarks
10
