ML23003A170

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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  Constellation icon.png
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

UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

+ + + + +

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

+ + + + +

THURSDAY,

DECEMBER 15, 2022

+ + + + +

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

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 2

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

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 3

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.

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 4

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 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 5

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 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 6

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.

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 7

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.

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 8

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.

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 9

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 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 10

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 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 11

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 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 12

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?

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 13

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.

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 14

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 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 15

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 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 16

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 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 17

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 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 18

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.

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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 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 20

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 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 21

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 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 22

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 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 23

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 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 24

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 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 25

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.

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 26

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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If you have any comment on the meeting, please contact

us and we'll provide the forms. If there are no

other questions or comments, meeting is adjourned.

Thank you.

(Whereupon, the above-entitled matter

went off the record at 10:33 a.m.)

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