ML23009A587

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

ML23009A587
Person / Time
Site:	Limerick
Issue date:	01/11/2023
From:	Bhagwat Jain NRC/NRR/DORL/LPL4
To:	Constellation Energy Generation
References
EPID L-2022-LLA-0140
Download: ML23009A587 (1)

Text

January 11, 2023 LICENSEE:

Constellation Energy Generation, LLC FACILITY:

Limerick Generating Station, Units 1 and 2

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 (EPID L-2022-LLA-0140)

On December 15, 2022, an observation public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Constellation Energy Generation, LLC (Constellation; licensee) via video conference. The purpose of the meeting was to discuss potential exceptions for independence and operating bypass in Clauses 5.6.1, 6.6 and 7.4 of IEEE-603-1991 as identified in staffs Limerick Generating Station, Units 1 and 2 (Limerick) digital instrumentation and controls (I&C) license amendment requests acceptance letter dated December 9, 2022 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML22339A064). The meeting notice and agenda, dated December 5, 2022, are available in the at ML22347A252. The presentation used by the Constellation representatives is available at ML22347A153. A list of attendees is provided in the enclosure. An official transcript of the meeting proceeding is available at ML23003A170.

The Limerick digital I&C license amendment requests were submitted on September 26, 2022 (ML22269A569), and supplemented on August 12, 2022 (ML22224A149). After receiving a license amendment request, the NRC staff conducted an acceptance review to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete a detailed technical review. The staff in its acceptance review decision on December 9, 2022 (ML22339A064) noted that Constellation is taking exception for independence and operating bypass in Clauses 5.6.1, 6.6 and 7.4 of IEEE-603-1991, correspond to similar requirements in IEEE Standard 279-1968, that are required to be met for proposed protection systems at Limerick in accordance with Title 10 of the Code of Federal Regulations 55.55a(h)(2). The staff requested Constellation to address this potential compliance issue of a high priority licensing concern in a public meeting.

The licensee discussed the potential compliance issue and informed the staff that it had provided its review comments in the Westinghouse Licensing Technical Report (LTR) to ensure Emergency Operating Procedures (EOPs) and Severe Accident Guidelines (SAGs) overrides were described appropriately but the LTR miscategorized the overrides as operating bypasses.

Additionally, a typographical error in the LTR for clause 5.6.1 in IEEE Standard 603-1991, was not identified by reviewers.

The licensee clarified that the definition of an operating bypass in IEEE Standard 603-1991 specifically states that operating bypasses are used for mode changes. Furthermore, its review of the logic in the system for the emergency operating procedures and severe accident guidelines in the plant protection system indicated that these features (operating bypass) are not there to enable plant mode changes. The overrides that were described for this clause in the LTR did not fall under that category because it does not change the mode when those overrides take place. Constellation therefore concluded that overrides were miscategorized as operating bypasses and will be corrected in the next revision to LTR.

Additionally, Constellation informed the staff that there was a typographical error in the LTR that showed partial compliance for independence in the clause 5.6.1 of IEEE Standard 603-1991, instead of indicating a complete compliance. This error was self-identified.

The NRC staff asked several clarifying questions based on the licensees slide presentation, including clarification of the proposed timeline for docketing LTR revision(s). The staff informed the licensee that a deadline for submitting LTR and any additional documents on the docket will be required and that the current deadline of spring of 2023 is too broad. The staff need a much more specific deadline for the LTR revision to be docketed.

The staff also clarified its understanding that the licensee intends to supplement the docket with this LTR revision prior to the NRC issuing request for additional information (RAI), in lieu of using the RAI process as part of the open item audit. The licensee confirmed the staffs understanding of the process for providing the requested information going forward.

Summary:

1. Constellation will make corrections to the appropriate licensing amendment request documents.

Correct the classification of operating bypasses as overrides and change exception status of clauses 6.6 and 7.4 of IEEE Standard 603-1991 to full compliance, Correct typographical error for partial compliance for independence in the clause 5.6.1 of IEEE Standard 603-1991 to indicate a complete compliance.

2. Constellation will address the above issue within its corrective action program, the vendor's corrective action program, as well as vendor oversight program.

No regulatory decisions were made as a result of this teleconference. No members of the public identified themselves on the teleconference. No Public Meeting Feedback forms were received.

Please direct any inquiries to me at (301) 415-6303 or bhagwat.jain@nrc.gov or to Mr. Michael Marshall at michael.marshall@nrc.gov or (301) 415-2871.

Sincerely,

/RA/

Bhagwat P. Jain, Senior Project Manager Plant Licensing Branch IV 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 DECEMBER 15, 2022, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC REGARDING POTENTIAL COMPLIANCE WITH CERTAIN CLAUSES OF IEEE STANDARD 603-1991 IN LIMERICK DIGITAL INSTRUMENTATION AND CONTROLS LICENSE AMENDMENT REQUESTS (EPID L-2022-LLA-0140)

Attendee Organization Bhagwat Jain U.S. Nuclear Regulatory Commission (NRC)

Steve Wyman NRC Khoi Nguyen NRC Eric Benner NRC Samir Darbali NRC Ming Li NRC Michael Marshall NRC Ed Miller NRC Alvarado Rossnyev NRC Richard Stattel NRC Michael Waters NRC James Berg Constellation Energy Generation, LLC (Constellation)

George Bonanni Constellation Kevin Cawley Constellation John Connelly Constellation David Helker Constellation Paul Krueger Constellation Mark DiRado Constellation Kayla Love, Marriner Constellation Steven R Hesse Constellation Ashley Rickey Constellation Mark Samselski Constellation Scott Schumacher Constellation Gerald Segner Constellation Warren Odess-Gillett Westinghouse Alan Campbell Nuclear Energy Institute Pareez E. Golub Sargent & Lundy Engineers Mark Lloyd Dominic Mocello Boyan A. Setchenski

Package: ML23009A562 Meeting Notice: ML22311A506 Handout: ML22319A001 (Constellation)

Meeting Summary: ML23009A587 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL1/LA NRR/DEX/EICB/BC NAME BJain KEntz MWaters DATE 1/9/2023 1/11/2023 1/9/2023 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL4/PM NAME HGonzález BJain DATE 1/10/2023 1/11/2023