ML23003A170

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

ML23003A170
Person / Time
Site:	Limerick
Issue date:	12/15/2022
From:	Bhagwat Jain NRC/NRR/DORL/LPL4
To:	Constellation Energy Generation
Sreenivas V, NRR/DORL/LPLI, 415-2597
References
EPID L-2022-LLA-0140
Download: ML23003A170 (28)

Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

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 Digital LAR Docket Number:

(n/a)

Location:

teleconference Date:

Thursday, December 15, 2022 Work Order No.:

NRC-2208 Pages 1-26 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1716 14th Street, N.W.

Washington, D.C. 20009 (202) 234-4433

1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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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 DIGITAL LAR

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THURSDAY, DECEMBER 15, 2022

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The meeting was convened via Videoconference, at 10:00 a.m. EST, Bhagwat Jain, Office of Nuclear Reactor Regulation, presiding.

NRC STAFF PRESENT:

BHAGWAT JAIN, NRR/DEX/ESEB ERIC BENNER, NRR/DEX MICHAEL MARSHALL, NRR/DORL/LPL1 RICHARD STATTEL, NRR/DEX/EICB MICHAEL WATERS, NRR/DEX/EICB

2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com ALSO PRESENT:

GEORGE BONANNI, PECO Energy JOHN CONNELLY, Constellation Nuclear MARK DIRADO, Constellation Nuclear WARREN ODESS-GILLETT, Westinghouse ASHLEY RICKEY, Constellation Nuclear MARK SAMSELSKI, Constellation Nuclear

3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com P R O C E E D I N G S 10:00 a.m.

MR.

JAIN:

Hello, good

morning, everyone. My name is BP Jain, and I'm a Senior Project Manager in NRR's Division of Operating Reactor Licensing. Along with Mike Marshall, we perform the project management function for all things digital in NRR.

A little background for today's meeting.

On December 9, the staff issued acceptance letter to Constellation Energy to review the Limerick Digital I&C LAR dated September

26.

In the

LAR, Constellation Energy had identified potential compliance issues with certain clauses in IEEE Standard 603, 1991.

The purpose of today's meeting is to discuss those compliance issues further and to gain a better understanding of the issues and eventually identify a regulatory path forward.

Today's meeting is scheduled for one and a half hours. If you have comments or feedback on any aspect of the meeting, please contact me or Michael Marshall. We'll provide the necessary forms.

And our contact information is provided on the public meeting notice posted on the NRC website.

4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com So we'll display the presentation Constellation will be making today. Those who do not have access to Teams video portion, you can download the Constellation presentation using ADAMS ML number for the presentation. Its ML number is 22347A153.

I'll repeat, the Constellation presentation ML number is 22347A153.

That information is also provided in the chat, and you can access that from the public meeting notice.

Now, I'll go over a couple of point of etiquettes. Please allow the presenter to make the presentation. There will be an opportunity to ask questions or provide comments after the presentation.

If you are not speaking, please keep your cellphone on mute. And when you speak, please identify yourself.

We have a court reporter taking -- making the transcript of the conversation, so please identify yourself so it reflects correctly on the meeting notes.

I will start with a few introductions.

We have executives from NRC in the meetings. Eric Benner, the Director, Division of Engineering and External Hazards. Then we also have several other

5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com NRC staff online. As they contribute to the meeting, they will introduce themselves.

I will now request Eric Benner to make opening remarks, please. Eric.

MR. BENNER: Okay, thank you, BP.

So I want to start. BP, can you change your window?

MR. JAIN: I will.

MR. BENNER: It seems duplicative.

Okay, thank you.

I think a real important thing I want to start with the messaging today is we have accepted the Constellation LAR for review. While we were doing our acceptance review we had a public meeting where we discussed a number of issues to determine whether those issues were acceptance review issues.

There was one issue that was an acceptance review issue.

Constellation has subsequently provided sufficient information for us to resolve that issue, and that has allowed us to move forward with acceptance.

During that previous public meeting, we raised this same potential compliance issue, and it was left sort of open as to when and how that issue would be resolved. As we completed our acceptance

6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com review, we wanted to make sure that Constellation was aware that this issue remained a challenge.

We had enough to start our detailed technical review, but it was an issue that was going to need to be resolved before we would be able to approve the license amendment.

So we put that information in our acceptance

letter, and we really appreciate Constellation's willingness to have this quick discussion with their -- regarding their proposal as to how to address the compliance issue. Because on its

face, what we've seen in Constellation's presentation appears reasonable.

We don't make regulatory decisions in public

meetings, but we have looked at the information and we look forward to the presentation.

And we look forward to having, you know, having clarity on how this issue's going to be resolved in a manner that would allow us to subsequently approve the license amendment request.

So with that, I look forward to the discussion. I think it continues the good discussion we were having in the pre-application phase and during the acceptance review. So that I think bodes well for the success of the review.

7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com And with that, I will turn it over to Constellation to see if they wish to make any opening remarks or jump into their presentation.

MR. JAIN: Mark, Constellation, please?

MR. DIRADO: Sure.

MR. JAIN: Make any opening remarks.

MR. DIRADO: I will. This is Mark DiRado, I am the Director of the Centralized Design Organization for Constellation. Appreciate the opportunity to provide some opening remarks here, and thank you for the kind words, Director Benner.

And we also appreciate the NRC staff completing the acceptance review in a timely fashion and providing us the opportunity to work with the NRC to resolve emergent questions expeditiously.

So with that, we agree, we're not asking for a regulatory decision to be made on this phone call. However, we would like to information related to the compliance issue that was raised on our path forward for resolution.

I will add that the issue itself is being captured within our corrective action program, the vendor's corrective action program, as well as our vendor oversight program. And we'll be to speak to additional actions there.

8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com And as far as our compliance issues go, the item of concern is the only exception that we can for this. We don't believe there's an extended condition beyond this particular issue.

And with that, I'll end my opening remarks there. And we look forward to a good open discussion. Thank you.

MR. JAIN: Thank you, Mark. Now I'll ask Ashley of Constellation to make your presentation.

Ashley.

MS. RICKEY: Sure. Good morning, everyone, this is Ashley Rickey. I am filling in for Frank Mascitelli today as --

MR. JAIN: Can share a screen?

MS.

RICKEY:

Licensing from Constellation. Yup, I'm sharing my screen right now if you can --

MR. JAIN: Yes, perfect.

MS. RICKEY: Please let me know when you can see that, okay. So thank you to Eric and Mark.

We have completed our opening remarks. So with that, we will go into the presentation, and we will start with our first slide here.

And John Connelly, please take it away.

9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. CONNELLY: Actually, this will be Mark Samselski.

MS. RICKEY: Oh, okay, thank you. Mark, go ahead.

MR. SAMSELSKI: Good morning, everyone, this is Mark Samselski, the responsible engineer. I just want to do a quick mic check. Can everyone hear me?

MR. CONNELLY: Yeah, we can hear you.

MR.

SAMSELSKI:

Great, thanks, everybody.

So on this slide, we really wanted to capture and reiterate what we took away from the acceptance review letter. And I want to highlight the last bullet. And I think everyone so far has brought this to our attention. And today's conversation, I just want to reiterate.

So we're here to discuss the issue at hand for the IEEE-603 compliance exceptions that were identified in our license amendment request. And we're going to go over the next few slides here to cover the position for Constellation. Next slide, please.

On this slide, on slide No. 4, I'd like to just reiterate the vendor oversight and the Vendor

10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Oversight Plan that was executed during our review process for documents developed by our vendor, Westinghouse, for this project and the license amendment request.

Our plan, our Vendor Oversight Plan, requires the project team to follow the Constellation Owner's acceptance review process for external technical products. And this is a process and procedure that we have in place at Constellation.

We

provided, when we reviewed the documents we provided comments to ensure emergency operating procedures and severe accident guidelines.

And their overrides were described appropriately in the licensing technical report.

Additionally, there was another typo that was self-identified or identified earlier from IEEE-603 Clause 5.6.1, and this was not identified by reviewers. So as following our Vendor Oversight Plan, we've taken the following actions to ensure high quality in the system that's being developed.

We entered a

supplier fundamental management system entry. We've identified and -- the following corrective actions as part of the Vendor Oversight Plan in our action tracking system, as well as the vendor provided an entry into their corrective

11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com action program and issued a report for that, and we'll issue a report.

And we will review those reports and the results of those reports and ultimately ensure that the licensing technical report is revised appropriately. And this is all in accordance with our Vendor Oversight Plan and our corrective action process at Constellation. Next slide, please, Ashley.

So on slide 5, we're going to dig into some of the details on IEEE-603, Clauses 6.6 and 7.4.

As I indicated on the previous slide, we provided comments to ensure emergency operating procedures and our severe accident guidelines overrides are described appropriately in the licensing technical report during the review process.

Subsequent to the first acceptance review meeting that we had, I believe it was last month, the Constellation team reached out to industry experts to aid in the understanding of your -- of the operating bypass definition in the context of emergency operating procedures and severe accident guidelines.

We had several discussions with IEEE standard working group members, and that identified that the operating bypasses by definition really are

12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com there to permit plant mode changes, as described in IEEE-603 1991 and IEEE-279.

We went back and we performed an additional review of how we applied logic in the system for the emergency operating procedures and severe accident guidelines in the plant protection system. And it really revealed to us that these features are not there to enable plant mode changes.

The logic that was developed to support the emergency operating procedures and severe accident guidelines are overrides to ensure that the appropriate safety function can be executed in the system.

So when we performed our review and we reached out to all the industry working group members for the IEEE standards that were referenced here, we miscategorized our overrides as operating bypasses.

And subsequently our plan will be to correct this miscategorization, and we'll discuss that further and how we're correcting those in later slides. But in an -- in a subsequent LTR revision.

I'll open it up to any questions that we may have at this time.

MR. STATTEL: This is Rich Stattel, can you hear me?

13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. SAMSELSKI: Hi, Rich, yes.

MR. STATTEL: Okay, I don't have any questions, I understand your change in this position.

And we had had similar discussions internally at the NRC and we understand this position. So we think we can go forward with evaluating the revised justification that you would be providing.

Thank you.

MR. SAMSELSKI: Okay, thank you, Rich, for that information. Anything else? If not, I'll turn it over to Warren for slide No. 6.

MR. ODESS-GILLETT: Good morning, this is Warren Odess-Gillett. I'm the licensing lead for the Limerick project from Westinghouse. And this is just going into more detail to what Mark had just summarized.

And that after further evaluation of IEEE Standard 603, 1991, and the definition of what an operating bypass is, we see in the note, and it's highlighted

here, that specifically operating bypasses are used for mode changes.

So to Mark's point, the overrides that were described for this clause in the LTR don't really fall under that category because we're not actually doing mode changes when those overrides take place.

14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com But they're in case of a -- of an emergency or a severe accident situation.

So with that, keeping that in mind, in fact, the PPS operating bypasses do meet -- do meet the criteria of 279 to 603. And that the bypass will be removed automatically whenever the permissive conditions are not met.

And these -- and the overrides that Mark referred to in the EOPs and the severe accident guidelines are not operating bypasses, as he said, per this definition.

So with this decision of full compliance, we are -- Constellation is not going to take action to request an alternate compliance to 50.55 -- per 50.55(a)(z),

as discussed during the previous acceptance review meeting held in November 10. Next slide.

MR. STATTEL: Warren, this is Rich Stattel.

MR. ODESS-GILLETT: Yeah, Rich.

MR. STATTEL: Couple quick questions.

This note that you have on the slide here, is -- I don't see that note in the clause of IEEE-603, 1991.

Is that -- is that taken out of the standard?

MR. ODESS-GILLETT: This is a -- this is

15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com a cut-and-paste from the standard in the definition section of the standard.

MR. STATTEL: Oh, okay, I see, it's in the definition section.

MR. ODESS-GILLETT: Yeah.

MR. STATTEL: Okay, thank you. I just wanted that clarification. And go ahead and continue. I have another question, but I'll wait

'til you finish.

MR. ODESS-GILLETT: Okay. So changes to the licensing technical report. So accordingly, based on the two issues, one being classifying those overrides as operating bypasses in 603 compliance and also the typographical error for partial compliance for independence in the clause for 603 in that table, those will be changed so that the partial compliance will indicate a complete compliance.

And for Section 7 for the operating bypass, Clauses 6.6 and 7.4, those will change from exception to comply, to C. And then the Section 3328 that explains why those exceptions were there originally, we're going to revise that section, and we'll show what that looks like on the next slide.

And we're expecting -- so we're expecting that as the NRC goes through its review process, we

16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com anticipate there will be other clarifications or other, maybe other issues with the LTR. I mean, the NRC has just begun their review now. And so it's kind of expected that the -- there might be some issues that might arise as the review continues on the LTR.

So we anticipate that there'll be other changes as the NRC review proceeds. This does not mean that we're -- now, the statement here that says the LTR during the final design process, additional changes. But that's not really planned at all.

There are no planned design changes to impact the LTR.

But the, it's more the expectation that there'll be other changes due to the RAI process that other changes to the LTR will be made.

And based on I guess where things are in the spring, we would consider a process in which the NRC could see how the revision looks like as we progress through the review process what the -- what the LTR changes will look like in the Westinghouse portal system. We can talk more about that if you wish.

But when the -- when both the NRC -- when the NRC feels that it's completed its review

17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com sufficiently to not anticipate any other changes to the LTR, that's when we would like to submit the LTR on the docket to minimize the number of revisions that would be necessary to have the LTR revised and reflect a complete description of the modification.

Any questions on this slide?

MR. MARSHALL: Yes, Warren, I have a couple -- actually more comments, I guess, than questions. With regards to providing us a revised LTR, we're probably going to -- well, we're not probably, we're going to need to set a deadline for any additional documents you plan on submitting to the docket like that.

And we can handle that through the normal scheduling discussions between the licensing part of the NRC and the licensing part of Constellation. But we need to make sure the dates for anything that you're adding to the docket supports the completion date that we've communicated to Constellation.

And the spring of 2023 is a little too broad of a window, and we probably need a much more specific deadline for the LTR revision to be provided.

The other comment is my understanding is that instead of using the RAI process, as part of the

18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com open item audit, my understanding, and someone from Constellation please correct me, is that Constellation intends to supplement the docket with this LTR revision prior to the NRC sending RAI. So we wouldn't necessarily even enter the RAI process at this point.

So is my understanding correct that in lieu of us sending you RAIs, that Constellation intends to revise the LTR as it based on our discussions and interactions that we've had today and will have in the future on the open item audit process that we're currently in?

MR. ODESS-GILLETT: Yeah, we would like

-- this is Warren Odess-Gillett -- we would like to follow that format because it worked very well for the Waterford Core Protection Calculator review where we, in the open item list, we specified exactly how the LTR will be revised to address the open item.

And then we put on the Westinghouse portal a draft of the LTR showing how it will look as we proceed through the item issue -- open items. And then at the point in which, as you say, Michael, there's a deadline where you need this thing docketed, that would be the time that we would actually do that.

19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. MARSHALL: Okay, understand. That's the only feedback I had or points I wanted to raise on this slide. Thank you.

MR. ODESS-GILLETT: Okay, so this slide is showing basically how this section in the LTR about operating bypasses and compliance will be revised, basically striking out the description about the overrides for the emergency operating procedures severe accident guidelines as a context for operating bypasses.

And just make simply the statement that the operating bypasses, using the definition from 603 1991, that the PPS is going to be in compliance with that clause. Next slide.

And then for the table itself, the changes would be reflected here, with 5.6.1 with the partial compliance indicated originally for between redundant portions of a safety system.

This is under the clause independence.

That that would be changed to fully comply as to be consistent with the description in 3.5.14.1 in the LTR that describes how the PPS is compliant with that clause.

And then for 6.6 and 7.4 with the changes that we -- that I described in the previous slide, we

20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com would change the Es of exception to Cs for compliance for those two sections in the conformance table, compliance conformance table. So that's what the LTR revision would look like.

And I think that is the -- that concludes the technical portion of the presentation.

MS. RICKEY: That's correct, thank you, Warren. We'll open it up at this point for any questions that anyone has that haven't been addressed or raised already.

MR. STATTEL: Okay, this is -- this is Rich Stattel. I have just a couple of questions.

It's more for the licensee, though.

So can you confirm that essentially this revised position, the compliance position, you -- the existing system on your existing licensing basis, that also is compliant. Do you consider that to be the case?

MR. SAMSELSKI: Hey, Rich, this is Mark Samselski. Yeah, when we went and looked back, we are in compliance with the clauses as it stands right now.

MR. STATTEL: Okay. So the functionality that you have in your current systems, your current license systems, that is being carried over directly

21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com into the revised BPS. So the functions will be the same, is that correct?

MR. SAMSELSKI: The ability to perform the functions that we administratively control in the new system are being carried over, correct.

MR. STATTEL: Okay. But they -- but you have, in your current system you have automatic bypass removal of some operational bypasses, and those functions are also being carried directly over into the new system.

MR. SAMSELSKI: Yes.

MR. BONANNI: Rich -- go ahead, Mark.

MR. SAMSELSKI: No, go ahead, George, if you.

MR. BONANNI: Rich, the answer to your question is yes, operating bypasses that support mode switch position changes. For example, you know, reactor power for bypassing the turbine trip. Do that based upon our main steam line pressure, and that signal will be automatically removed when it is no longer applicable.

That's the way it is now in the current system, and that will be carried over to the future system.

MR. STATTEL: Okay. I thought that was

22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com the case. I just wanted to get that confirmation.

Thank you very much.

MR.

SAMSELSKI:

Thanks, George, appreciate that.

MR. JAIN: With that, are there other questions or comments or feedback for Constellation or for NRC staff from anyone? You can all --

MR. WATERS: This is Mike Waters. And it seems like there's a great comfort level for the path forward on this. I guess in terms of what's the proposal from the Constellation the next steps is to formally put this response and issue into the current open item list. Is that the next step that's being proposed?

MR. SAMSELSKI: Yeah, I think -- Mike, this is Mark Samselski again. Yeah, we'll put it in the open item list. I'd like Pareez to make sure that that's the appropriate location based on the agreements that we had. And then we'll track this as Warren described and update the documents appropriately.

MR. MARSHALL: Hey, Mark, this is Michael

-- Mike, this is Michael Marshall, and for Mike Waters. I think with regards to the review, at the very least at least the appropriate open items needed

23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com to be added to this if they're planning on closing these as open items and doing that through the revised LAR.

Because right now, well, we don't have open items on these two items right now. So we probably need to track that to make sure this doesn't fall through the cracks when they update the LTR.

MR. WATERS: Absolutely.

MR. MARSHALL: That's where I think as far as the review project itself, that's where that type of tracking needs to occur.

MR. STATTEL: Hey, Michael, this is Richard Stattel, we do -- we did write open items.

MR.

MARSHALL:

But we haven't transmitted it to them yet, Rich. So they don't have them.

MR. STATTEL: Oh, we haven't sent them.

MR. MARSHALL: Sorry, yeah, sorry.

MR. STATTEL: Just so we're clear, I wrote open items on these, and we will resolve those through the open item process. And just to confirm, there's no need for me to write an RAI, a formal RAI on these.

MR. MARSHALL: No. There's no need for you to change that open item you have. It's internal

24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com to the NRC. We have not transmitted that to the licensee yet.

And with the way we set up the open list process, they can't add stuff to the open items list.

That has to come -- be sent from us to them. And so we haven't had that step yet. So when I was talking, I was talking with regards to what Constellation has access to.

MR. STATTEL: Okay, thank you very much.

MR. MARSHALL: No problem.

MR.

SAMSELSKI:

And

Michael, I

appreciate you discriminating between those, because I have my own open items list that I have in our corrective action program that's tracking these. So I appreciate you differentiating that. Thank you.

MR. JAIN: So if there are no other questions for the Constellation or the NRC staff, and I'll ask Michael or Mike to recap the meeting, today's meeting.

MR. MARSHALL: BP, before you do a recap of the meeting, since we're well ahead of schedule, I think now might be a good time to open the floor up to -- for the NRC to receive any questions or public comments.

MR. JAIN: Oh, yes. Yeah, I was going

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com to say that you can also provide your feedback in writing or after the meeting via email or myself.

And the floor is open for public or anyone really to provide their comments.

So I guess I don't hear any question or comment, so Michael, you want to recap the meeting?

MR. MARSHALL: Okay. Yes, I will. With regards to the issues that we have discussed before with the exceptions with regards to IEEE-603, we have a clear understanding of the path forward and the resolution to those questions we had raised.

And at this point we think the only thing needed going forward is for that -- those changes to the LTR or in the larger sense the license amendment request that Constellation submitted to us, that does have to be submitted to us and on the docket at a certain point.

And we've talked about that occurring as part of the open item audit process, when the licensee will be revising the LTR. And the only thing that's outstanding there is the need to set an actual deadline for when that will occur. And we will do that through the normal discussions between Constellation and the NRC on the schedule for this review.

26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com But again, this is a very helpful discussion. And as Eric and Mark said at the beginning of this meeting, I think these exchanges are very helpful, especially in getting to resolution of issues that we identify as quickly and as early as possible.

And going forward, I know the NRC staff, and from talking with Constellation and their leadership, I think that's one thing both parties wants to do is identify issues early, resolve those issues early so they don't linger and possibly disrupt this review later down the path.

And I think this is a fine example of our mutual commitment to that approach for this licensing action.

MR. JAIN: Thank you. Constellation would like to make any closing remark? Or any of the participants?

MR. DIRADO: Michael summed it up well and we agree. Expeditious closure of comments is paramount to us having a good outcome and safe outcome with this project. And we appreciate the opportunity to dialog further as any other issues arise.

Thank everybody for their time.

MR. JAIN: Well, thank you for your time.

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Thank you.

(Whereupon, the above-entitled matter went off the record at 10:33 a.m.)